INTRODUCTION

This policy ("Policy/s") explains how we collect and process your data in our capacity as a personal data controller.

YOUR RESPONSIBILITIES

Please read this Policy and review it regularly.
If you are in a contractual relationship with us, please check the related terms and/or policies: they may contain further details about how we collect and process your data.
Please also pay attention to additional information and conditions that we introduce you to at various stages of our interaction.
If you provide us with personal information about other people, or if others provide us with your information, we will only use that information for the specific purpose for which it was provided to us. If you provide us with information about third parties, you should have a legal basis for this, and you should also inform the third parties of the way in which we will process their data, including with this Policy.

WHO ARE WE AND HOW TO FIND US? 

We, "BG Domoupravitel" EOOD, EIC: 202096738, headquarters and address of management: city of Plovdiv, "Centralen" district, 20 "Kavala" street, floor 3 (hereinafter referred to as "us", "we" or the "Company"), we are the controller of and responsible for your personal data.
If you have any questions about the Policy or about your personal data, please contact us.
Contact details with us: 
Address: city of Plovdiv, "Centralen" district, "Kavala" street No. 20, floor 3, e-mail: info@bgdomoupravitel.bg
It is very important that the information we have about you is correct and up-to-date. Please inform us of any changes or if you notice any errors.

WHAT DATA OF YOURS DO WE PROCESS, FOR WHAT PURPOSE AND ON WHAT BASIS?

We process personal data for specific purposes and on relevant legal grounds, depending on your role with us.

When you are a visitor or user of our website www.bgdomoupravitel.bg
A) Automatically collected information: You may access the website without entering personal data. But even in this case, certain information is automatically processed - log files /event files/.
We process log files /event files/ on the basis of "legitimate interest", the purposes being security, technical support and/or prevention/detection of violations/crimes.
B) Social plugins or buttons /Social Plug-in/ Facebook, Instagram, Twitter and/or others. Their use is at your discretion. They represent a link to third-party websites that collect and process personal data according to their terms/policies. For your information and rights, please familiarize yourself with the terms/policies of the relevant third parties.
We have placed these plugins/buttons to make our website more functional for visitors and also to promote our business if you voluntarily share our content on relevant websites. We accept this as our "legitimate interest" and accordingly apply the "legitimate interest" basis for data processing under this letter B). More information about the social plugins used can be found here.
C) Other links to third party websites.
Our website may also link to other websites. If you choose to follow these links, please read the privacy policies of the respective websites in detail to understand how your information will be handled. The use of these links on our website is based on our "legitimate interest" in making the website more functional for visitors, as well as our and the relevant third party's "legitimate interest" in developing our business.
D) Personal data that you provide to us through the website.
When you use the contact form on our website (if one is available at the relevant time) or another of our services on the website, we process the personal data for the purpose for which you provide it to us, i.e. according to the specific function and your request. The required fields that we have provided (if any) are the minimum information that we have determined that we need. Please do not provide us with personal information about you that is not necessary for the relevant purpose. We also process the information that is created in view of our interaction, for example the content itself of the messages sent through the website.
Sometimes we process your data in the so-called pre-contractual ground (ground "for taking steps at the request of the data subject before entering into a contract"). We apply this basis in all cases in which you request to conclude a contract with us and we process your necessary data for this purpose. In other cases, there may be a concluded contract between us and the processing of your personal data through the website is in connection with the performance of our contractual obligation (ground "for the performance of a contract to which the data subject is a party").
In the cases under Art. 6 of the Electronic Document and Electronic Authentication Services Act (e.g. when you send a message through the contact form on the website www.bgdomoupravitel.bg), we store information about the time and source of the transmitted electronic statements for a period of one year. We do this on the grounds "to comply with a legal obligation that applies to the Company". The aim is to comply with the relevant legal obligations.
In other cases (for which no other reason is specified in this letter "D)"), the reason for processing your data is our "legitimate interest" to respond to/fulfill your request.
E) Sensitive data about you /special categories of data/.
We do not require you to provide us with such data about you. Special categories of data, or "sensitive data", are personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data for the sole purpose of identifying a natural person, data on the state of health or data on the sex life or sexual orientation of the natural person. Please do not provide us with such data. Providing such data, as well as other personal data that is not necessary for the relevant purpose of our interaction with you, exposes your data to unnecessary risk.

4.2. If you are a visitor to our office:
In this case, we will ask you to introduce yourself and provide us with basic information about yourself /your names, organization you work for or represent/. We may also reflect the day you visited us, possibly the specific time, as well as information about the persons you met.
We will use the information received on the basis of our "legitimate interests" - to control access to our office and for security reasons. We could also use the information to report/control the activities of the Company, as well as the activities of its members and bodies with whom you meet.

4.3. If you are a participant in an event (presentation, meeting, forum and other events) or initiative that we organize and/or in which we participate:
We will collect the necessary information for your inclusion and participation. Sometimes we may ask for information about your preferences to make the event/initiative more useful.
In some cases, audio, video, audio-video recordings and/or photographs may be taken in connection with the events/initiatives (eg during the events and initiatives themselves). We may use such photos/recordings as well as information about your participation to promote our event/initiative in the media, on social networks, on our website, in a presentation and/or otherwise. When publishing recordings/photos with you on a social network and/or on our website, it is possible to indicate persons participating in the event/initiative, for example through a tag function. If the making, storage and/or use of audio, video, audio-video recordings and/or photographs of you is of concern to you, you may inform us in advance (for example, that you do not wish us to publish information about you and/or that you do not you want us to publish recordings/photos of you) and we will consider how to proceed on a case-by-case basis.
We may also retain your details to contact you from time to time and send you information about other similar events/initiatives of ours. We may also ask you for feedback on how you rate our event/initiative, in order to analyze, plan and/or improve our operations.
Those described in this point 4.3. we carry out data processing activities based on our "legitimate interests" to fulfill the purposes specified in this point.
You have the right to object to the above ways of using your data as described below in relation to your rights.

4.4. If you are a participant in our campaign.
We could organize such campaigns, for example through our social network profiles. In these cases, we will process the information you provide to us for the purpose of your participation in the relevant campaign, based on our "legitimate interest" in running the relevant campaign.

4.5. If you "like"/"follow" us on a social network.
If you have "liked" and/or "followed" our profile/page on a social network, in accordance with the practices of the relevant social network, you may automatically see messages, posts and/or materials published by us. If you make an inquiry to us through the relevant social network or comment on a publication, we may use the functionalities of the same network to respond to you, and if you have requested that we contact you in another way /for example, by giving us your phone number/, we will comply with your wish.
We will process this data based on our "legitimate interests" to promote/improve our business and/or respond to you.

4.6. If you are a person with whom we contact in connection with contractual relations of the Company:
This means that you are our partner, customer or supplier or represent an organization that is our partner, customer or supplier or are an employee of it. The company concludes contracts in its capacity as a professional manager-trader under the Condominium Management Act (ZUES) and processes data in this connection - for example, data on owners, users and residents of objects in the condominium, data on the objects in the condominium, data for payments, etc., as required by law. We may also process the following information: written/electronic or other correspondence with you; data contained in documentation relating to our relationship, for example your signatures, description of your conduct, your statements, etc.; any other information we need in connection with the relationship in which we are involved.
If you are a party to a Contract with us:

• for the purposes of fulfilling our obligations under the Contract with you, we will process the information on the basis "for the performance of a contract to which the data subject is a party".
• we will process information on the basis "to comply with a legal obligation that applies to the Company" when this is required by applicable legislation (e.g. under the GDPR);
• the remaining processing activities will be carried out on the basis of our "legitimate interests" to seek/report the performance of the contract between us and with a view to the possible establishment, exercise or defense of legal claims.

If you represent an organization that is our partner, customer or supplier or are an employee of it:

• we will process information on the basis "to comply with a legal obligation that applies to the Company" when this is required by applicable legislation (e.g. under the GDPR);
• the remaining processing activities will be carried out on the basis of our "legitimate interests" to perform and seek/report the performance of the contract between us and with a view to the possible establishment, exercise or defense of legal claims.

4.7. If you are a person with whom we contact in connection with the possible conclusion of a contract:
This means that you are our potential partner, customer or supplier or represent an organization - our potential partner, customer or supplier or are an employee of it. We may have your information from yourself, as well as from a professional public register, from a person you have worked with or know for other reasons, you have given us your business card or contacts at an event, meeting or otherwise. In these cases, we will make an assessment for what purpose and on what basis we could use your contact details. We will take into account the context in which this occurred and your reasonable expectations regarding our use of the personal data.
If we consider that there is a "legitimate interest" basis for us to contact you in order to provide/request an offer, to offer you a partnership or for any other purpose to communicate with you in connection with a possible future contractual relationship with the Company, You you will have the right to object to such use of your data as described below in relation to your rights. If you request to enter into a contract with us, we will process your necessary data for this purpose on the basis "to take steps at the request of the data subject before entering into a contract". In some cases we may need to ask for your consent, and if you give it, we will process your data on the basis of 'consent'.

4.8. In other cases (outside of those specified above in this item 4), if you are a person we contact in connection with the implementation of the Company's goals
The purpose of such data processing is to achieve the Company's goals. This includes, for example, the cases of data processing of natural persons working in various authorities/institutions.
The above-mentioned processing is on the basis "for compliance with a legal obligation that applies to the Company", when this is required by the applicable legislation (e.g. according to ЗУЕС), or on the basis of "legitimate interest", which consists in carrying out the purposes of The company.

4.9. For what other purposes may we use your personal data?
We have described the most typical purposes for their processing above, but you should also consider the following purposes:

• for the administration of our activity, including reporting and analysis within the Company itself - we apply the basis of our "legitimate interest";
• prevention of fraud and other illegal activities - we apply the basis of our "legitimate interest";
• to establish, exercise and/or defend our legal claims - we apply the basis of our "legitimate interest";
• to fulfill our obligations under a contract to which you are not a party - we apply the basis of our "legitimate interest";
• to analyze the effectiveness of our activity and its improvement - we apply the basis of our "legitimate interest".
• for the performance of our obligations under a contract to which you are a party - we apply the basis "for the performance of a contract to which the data subject is a party";
• for the fulfillment of our obligations applicable by law (e.g. under the EUES and/or under the accounting legislation, tax legislation, etc.) - we apply the basis "for compliance with a legal obligation that applies to the Company".

4.10. On what legal basis do we process your data?
For the processing of your data, we apply legal grounds according to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and on the cancellation of Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as "GDPR".

4.10.1. For compliance with a legal obligation that applies to the Company (Article 6, paragraph 1, letter c) of the GDPR)
These are the cases in which the processing of your personal data is necessary to comply with our legal obligation under the ŽUES, tax legislation, accounting legislation, etc.

4.10.2. Legitimate interest (Article 6, paragraph 1, letter f) of the GDPR)
When we define our legal basis as a "legitimate interest", we first assess what it is and whether the processing of your data is necessary to achieve it. We also assess whether your interests or fundamental rights and freedoms that require protection of personal data take precedence over it. Regardless of our discretion, you always have the right to object to processing based on our legitimate interests, as described below in item 10.1.4.
When we process your data on the basis of "legitimate interest", the description of the legitimate interest matches the description of the purpose of the data processing.

4.10.3. For the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to the conclusion of a contract (Article 6(1)(b) of the GDPR)
This can be applied when you yourself are a party to a contract with the Company, respectively when, at your request, steps are taken before concluding a contract with you.

4.10.4. Your consent (Article 6(1)(a) GDPR)
This is any freely expressed, specific, informed and unequivocal indication of your will, by means of a statement or clear affirmative action, which expresses your consent to the processing of personal data relating to you.
If we have to process your "sensitive data" (more information about them can be found in item 4.1., letter D) above) on the basis of your consent, the same should also be explicitly given. In item 10.1.7. you will find out how you can withdraw your consent at any time.
Note that consent is a different legal basis than those described above. For example, signing a contract between us is not equivalent to giving consent.

If you have concerns or doubts about what exactly is the applicable basis for a specific purpose of processing your data, you can always contact us.

5. CAN YOU NOT PROVIDE YOUR PERSONAL INFORMATION?

You are obliged to provide us with your personal data in the event that such a contractual or legal obligation exists. If in such cases you do not provide us with this data upon request, we may not be able to enter into or perform a contract or realize any of the other purposes of processing your data. In any case, we will notify you of this. We will also notify you if the provision of your data is a requirement necessary for the conclusion of a contract.

6. COMBINATION OF INFORMATION. OBTAINING DATA FROM OTHER SOURCES

Sometimes we combine information about you that we receive from you through various communication channels /for example, by email, phone, through our website/ or from other sources - public sources, such as the Commercial Register, the Register of Non-Profit Legal Entities and the BULSTAT register or from third parties – our partners with whom you interact in connection with your relationship with us. When we combine this information, we do not use it for a purpose of which you are not informed. When we receive information from sources other than yourself, this information is limited to what is necessary in relation to the purposes for which it is processed.

7. WHO DO WE SHARE YOUR PERSONAL DATA WITH?  

We may need to share your personal data with the parties listed below:
7.1. Service Providers. These can be hosting companies, service providers related to information technology (IT services), system administration, couriers, mobile operators, social networks.
7.2. Other persons who provide us with relevant services - banks, lawyers, professional consultants and insurers, event organizers and others - when this is necessary to provide us with a particular service.
7.3. Authorities - when this is necessary in order to achieve the goals of the Company, as well as in other cases according to the applicable legislation.

In cases of publication of your data (including those contained in photos, videos, etc.) on our website and/or in a social network, the data will become publicly accessible (in relation to social networks - as far as this corresponds of the relevant functionalities/settings). In cases of publication of your data in a social network, the recipient of the data is also the administrator of personal data in the relevant social network.

8. INTERNATIONAL DATA TRANSFER

The use of the platforms/tools/services of Google LLC (eg gmail) and/or Meta Platforms Ireland Ltd. (e.g. the social network Facebook, the Messenger service) could be related to the transfer of data outside the European Union (EU) and the European Economic Area (EEA). Such data transmissions are based on decisions regarding an adequate level of protection, standard contractual clauses, as well as possibly on your express consent (according to Article 49(1)(a) of the GDPR) and/or on another basis, if indicated in the Privacy Policies of those platforms/tools/services. For more information on this, you should read the relevant Privacy Policies (for Meta Platforms Ireland Ltd. - please visit https://www.facebook.com/privacy/explanation; for Google LLC - please visit https://policies. google.com/privacy?hl=bg), and you can also contact us for help using the contact details specified in item 3 of this Policy.
In all other cases, your personal data are not transferred to third countries (countries that are not members of the European Union and are not parties to the agreement on the European Economic Area) and are not transferred to international organizations.

9. DATA STORAGE PERIOD
     
   We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with legal requirements.
   When deciding on the exact period of data retention, we take into account applicable legal requirements (including those under the GDPR), the volume of the data, its nature and sensitivity, the potential risk of harm from unauthorized use or disclosure of the data, the purposes of the processing and whether they can be achieved by other means.
   According to tax legislation, we must keep certain documentation containing personal data for a period of five years.
   In the cases under Art. 6 of the Electronic Document and Electronic Authentication Services Act (e.g. when you send a message through the contact form on the website www.bgdomoupravitel.bg), we store information about the time and source of the transmitted electronic statements for a period of one year.
   In many cases, we will comply with the statute of limitations under applicable law.
   In some circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information for an unlimited period of time without further notice to you.
10. YOUR RIGHTS

Under the law, You have certain rights, including (but not limited to) You have the right to:
10.1.1. You request access to your personal data. You have the right to receive confirmation as to whether personal data relating to you is being processed. If this is the case, you have the right to access the data and certain information related to its processing, as well as the right to obtain a copy of this data.
10.1.2. You request correction of your personal data. You may require us to correct inaccurate personal data relating to you and/or supplement incomplete personal data relating to you (taking into account the purposes of the processing).
10.1.3. You request deletion of your personal data. This gives you the opportunity to ask us to delete/remove your personal data when there is no valid reason for us to continue processing it. You have the right to ask us to delete or remove your personal information also where you have exercised your right to object to processing (see below).
10.1.4. Objections to the processing of your personal data. You have the right, at any time and on grounds related to your specific situation, to object to the processing of your personal data on the basis of "legitimate interest", including in cases of profiling on this basis. In order to continue the processing, we must demonstrate that there are compelling legitimate grounds for the processing that take precedence over your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
In addition, you have the right to object in the following cases:

• You have the right at any time to object to the processing of personal data concerning you when we process it for direct marketing purposes, including in cases of profiling related to direct marketing. When you object to processing for direct marketing purposes, the processing of personal data for these purposes is terminated.
• Where personal data are processed for the purposes of scientific or historical research or for statistical purposes, you have the right, based on your specific situation, to object to the processing of personal data concerning you, unless the processing is necessary for the performance of a task , carried out for reasons of public interest.
  10.1.5. You request restriction of the processing of your personal data. This allows you to ask us to stop processing (except for certain processing actions provided for by applicable law) personal information about you, in the following cases:
• the accuracy of the personal data is contested by you, and the restriction of processing applies for a period that allows us to verify the accuracy of the personal data;
• the processing is unlawful, but you do not want the personal data to be deleted, but instead request the restriction of its use;
• we no longer need the personal data for the purposes of processing, but you require them for the establishment, exercise or defense of legal claims;
• You have objected to the processing pursuant to Article 21(1) of the GDPR pending verification of whether the legitimate grounds we apply take precedence over your interests.
  10.1.6. You exercise the right to portability of your personal data. If we process personal data on the basis of "performance of a contract to which the data subject is a party" or on the basis of "consent", you may require us to receive the personal data in a structured, widely used and machine-readable format and/or to transfer the personal data to another personal data controller.
  10.1.7. Withdraw your consent. In the event that we process personal data on the basis of your consent or express consent, you have the right to withdraw your consent at any time without prejudice to the lawfulness of the processing based on consent before it is withdrawn.
  You can see more about the above rights on the website of the Commission for the Protection of Personal Data: https://www.cpdp.bg/?p=element&aid=1045.

10.2. Exercising Your Rights. If you wish to exercise any of the rights specified above or receive more information about it, please send us an email to info@bgdomoupravitel.bg or send us a letter to our physical address specified in item 3.
You will not pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive, in particular because of its repetition, or we will refuse to fulfill your request in these circumstances.  
We may need to ask you for specific information to help us verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure that ensures that personal data is not disclosed to a person who does not have the right to receive it. We may also contact you to request additional information in connection with your request to expedite a response.
We try to respond to all legitimate requests within one month. Sometimes it may take us more than a month, in which case we will let you know.

11. YOUR RIGHT OF COMPLAINT TO A SUPERVISORY AUTHORITY.

If you are not satisfied with any aspects of how we process your data, you have the right to lodge a complaint with the relevant competent supervisory authority. The Commission for the Protection of Personal Data is the supervisory authority of the Republic of Bulgaria, defined by the Law on the Protection of Personal Data. Her contact details are as follows: address - Sofia 1592, "Prof. Tsvetan Lazarov" No. 2, GPS coordinates - N 42.668839 E 23.377495, phone +3592/91-53-555, e-mail - kzld@cpdp.bg, website - www.cpdp.bg. We would appreciate it if you would contact us first, in case of a complaint, so that we can try to help you.

12. MODIFICATION OF THIS POLICY

We have the right to change/update this Policy. We will post such changes/updates on our website www.bgdomoupravitel.bg