Privacy Policy

General Information

As of 25 May 2018, a new data protection regulation (General Data Protection Regulation) adopted by the European Union comes into effect. The regulation aims to ensure the protection of personal data of individuals from all EU member states and to harmonize the regulations for their processing.

As a personal data controller for the provision of training, translation, and legalization services, Intellect Agency Ltd complies with all requirements of the new regulation, collecting only personal data to the extent necessary for the provision of the service, and storing it responsibly and lawfully.

Information about the Personal Data Controller

1. Name: "Agency Intellect" Ltd.
2. UIC/BULSTAT: 201178972
3. Registered office and management address: Sofia, 70-72 Cherni Vrah Blvd.
4. Business address: Sofia, 70-72 Cherni Vrah Blvd.; 45 & 60 P. Evtimiy Blvd.; Andrey Lyapchev Blvd., bl. 261A; 1A Topli Dol St.; 1A Vasil Levski Blvd.
5. Correspondence details: Sofia, 70-72 Cherni Vrah Blvd.
6. E-mail: info@intellect.bg
7. Phone: 0700 13 002, 0878 44 74 70
8. Personal Data Administrator Certificate No. 419511/15.02.2016

Information about the Data Protection Officer

1. Personal Data Controller: Vanya Ananieva-Lyubenova
2. Correspondence details: Sofia, 70-72 Cherni Vrah Blvd.
3. Phone: 0878 447470
4. Email: v.ananieva@intellect.bg

Information about the competent supervisory authority

1. Name: Commission for Personal Data Protection
2. Registered office and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Phone: 02 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg

"Агенция Интелект" ООД осъществява дейността си в съответствие със Закона за защита на личните данни и Регламент (ЕС) 2016/679 на Европейския парламент и на Съвета от 27 април 2016 година относно защитата на физическите лица във връзка с обработването на лични данни и относно свободното движение на такива данни.

Legal Basis for Collecting, Processing, and Storing Your Personal Data

Art. 1. (1) Agentsia Intellect Ltd collects and processes your personal data in connection with the provision of training, translations and legalization pursuant to Art. 6, para. 1, Regulation (EU) 2016/679, and more specifically on the basis of the following:

• Explicit consent obtained from you as a client;
• Fulfillment of the obligations of "Intellect Agency" Ltd. under the contract with you;
• Compliance with a legal obligation applicable to "Agentsia Intellect" Ltd.;
• For the purposes of the legitimate interest of "Agentsia Intellect" OOD.

(2) Agentsia Intellect Ltd is a personal data controller with regard to your data as users of our services. With respect to the personal data that you process using our services, Agentsia Intellect Ltd acts in its capacity as a personal data processor.

Goals and principles in the collection, processing, and storage of your personal data

Art. 2. (1) Agentsia Intellect Ltd collects and processes the personal data that you provide to us in connection with the use of our services and for entering into a contract with the company, as well as for registering to participate in our events, including for the following purposes:

• individualization of a party to the contract;
• accounting purposes;
• statistical purposes;
• protection of information security;
• ensuring the performance of the contract for the provision of the respective service;
• sending informational messages and notifications about changes to the service;
• improving and personalizing the service by offering you suitable service offers that may be of interest to you;

(2) Agentsia Intellect Ltd adheres to the following principles when processing your personal data:

• lawfulness, fairness and transparency;
• purpose limitation of processing;
• relevance to the purposes of processing and minimization of collected data;
• accuracy and currency of the data;
• storage limitation in relation to achieving the purposes;
• integrity and confidentiality of processing and ensuring an appropriate level of security of personal data.

(3) In the processing and storage of personal data, "Agentsia Intellect" Ltd. may process and store personal data in order to protect the following legitimate interests:

• fulfillment of obligations to the National Revenue Agency, the Ministry of Interior, and other state and municipal authorities.

What types of personal data does "Intellect Agency" Ltd. collect, process and store?

Art. 3. (1) Agentsia Intellect Ltd performs the following operations with personal data for the following purposes:

• Registration of users of training and translation services in a customer management system. The Data Protection Officer considers that the operation "Conclusion of a training/translation agreement" is admissible and provides sufficient guarantees for the protection of the rights and legitimate interests of data subjects in accordance with the requirements of GDPR.
• Conclusion and execution of a commercial transaction with a client or partner - the purpose of this operation is the conclusion and execution of an agreement with a commercial partner or client and its administration;
• Sending informational messages – the purpose of this activity is to administer the process of sending messages to clients regarding improvements or changes in services, in accordance with the service provision agreement.
• Sending a newsletter – the purpose of this operation is to administer the process of sending newsletters to clients who have indicated that they wish to receive them;

(2) Agentsia Intellect Ltd processes the following categories of personal data and information for the following purposes and on the following grounds:

• Data: Your identifying data (first and last name, email, phone, date of birth)
  • Purpose for which the data is collected: 1) Registration of a user in the customer management system; 2) Establishing contact with the user and sending information to them, including upon expressed wish - for sending newsletters and promotional messages; 3) When filling out and submitting an application or inquiry through any of the forms on the current website;
  • Legal Basis for Processing Your Personal Data – By accepting the terms and conditions and purchasing a service, a contractual relationship is established between Agentsia Intellect Ltd and you, on the basis of which we process your personal data – Art. 6, para. 1, point (b) GDPR.
• Other data processed by "Agentsia Intellect" OOD – Upon entering our website or your profile, Agentsia Intellect Ltd collects data about the IP address used.
  • Purpose for which the data is collected: Improving the security of the service and localization of the interface, statistical and marketing research.
  • Legal Bases for Data Processing: Processing is necessary for the performance of a contract to which the data subject is a party - Art. 6, para. 1, point (b) of the GDPR. Until the creation of a user profile, the IP address is collected on the basis of the legitimate interests of the controller – Art. 6, para. 1, point (f) of the GDPR;
• Your data for issuing an invoice to an individual – If you wish to have an invoice issued to you as an individual, you must provide your personal identification number.
  • Purpose for which the data is collected: Issuing an invoice for making payments under a concluded contract for the provision of services for the use of the platform for creating online stores.
  • Legal Basis for Processing Your Personal Data – By accepting the terms and conditions or upon entering into a written contract, a contractual relationship is established between Agentsia Intellect Ltd and you, on the basis of which we process your personal data – Art. 6, para. 1, point (b) GDPR.

(3) Agentsia Intellect Ltd does not collect or process personal data that relates to the following:

• reveal racial or ethnic origin;
• reveal political, religious or philosophical beliefs, or trade union membership;
• genetic and biometric data, data concerning health or data concerning a person's sex life or sexual orientation.

(4) Personal data is collected by "Intellect Agency" Ltd. from the individuals to whom it pertains or from their authorized representatives.

(5) The company does not perform automated decision-making with data.

Retention period for your personal data

Art. 4. (1) Agentsia Intellect Ltd stores your personal data for a period of five years. After the expiration of this period, Agentsia Intellect Ltd takes the necessary care to erase and destroy all your data without undue delay.

(2) Agentsia Intellect Ltd stores the personal data that it is required to keep under applicable legislation for the respective prescribed period, which may exceed the duration of your registration.

Transfer of your personal data for processing

Art. 5. (1) Agentsia Intellect Ltd may, at its own discretion, transfer some or all of your personal data to personal data processors for the fulfillment of processing purposes in compliance with the requirements of Regulation (EU) 2016/679.

(2) Agentsia Intellect Ltd notifies you in the event of an intention to transfer some or all of your personal data to third countries or international organizations.

Your rights regarding the collection, processing, and storage of your personal data

Withdrawal of Consent for Processing Your Personal Data

Art. 6. (1) If you do not wish all or part of your personal data to continue to be processed by “Intellect Agency” Ltd for a specific or all processing purposes, you may at any time withdraw your consent for processing by filling out the form in your client profile or by submitting a free-text request.

(2) Agentsia Intellect Ltd may request that you verify your identity and that you are the person to whom the data relates.

(3) By withdrawing consent for the processing of personal data that is mandatory for creating and maintaining your registration to use the services, any information regarding completed training or translations will become inaccessible.

Right of access

Art. 7. (1) You have the right to request and obtain from “Intellect Agency” Ltd confirmation as to whether personal data relating to you is being processed.

(2) You have the right to access the data related to it, as well as the information relating to the collection, processing, and storage of your personal data.

(3) Agentsia Intellect Ltd provides you, upon request, with a copy of the processed personal data related to you, in electronic or other appropriate form, and in the case of an excessive number of requests, Agentsia Intellect Ltd reserves the right to impose an administrative fee.

Right to rectification or completion

Art. 8. You may correct or complete inaccurate or incomplete personal data by submitting a request to “Intellect Agency” Ltd.

Right to erasure ("right to be forgotten")

Art. 9.(1) You have the right to request that “Intellect Agency” Ltd delete your personal data, and “Intellect Agency” Ltd is obliged to delete them without undue delay when any of the following grounds apply:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
• You object to the processing of your personal data, including for the purposes of direct marketing, and there are no overriding legitimate grounds for the processing;
• the personal data have been unlawfully processed;
• the personal data must be erased for compliance with a legal obligation under EU law or the law of a Member State to which Agentsia Intellect Ltd applies;

(2) Agentsia Intellect Ltd is not obliged to erase personal data if it stores and processes them:

• for exercising the right to freedom of expression and the right to information;
• for compliance with a legal obligation requiring processing under EU law or the law of the Member State applicable to the Controller, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
• for reasons of public interest in the area of public health;
• for archiving purposes in the public interest, for scientific or historical research purposes, or for statistical purposes;
• for the establishment, exercise or defense of legal claims.

(3) To exercise your right to "be forgotten", you should submit a request through the option in your profile /in case you have a registration/ or a written request sent to "Agentsia Intellect" OOD, as well as verify your identity and that you are the person to whom the data relates before "Agentsia Intellect" OOD, by presenting your identification document in person.

(4) Agentsia Intellect Ltd does not delete data that it is legally obligated to store, including for defense against legal claims filed against it or for proving its rights.

Right to restriction

Art. 10. You have the right to request that “Intellect Agency” Ltd restrict the processing of your data when:

• you contest the accuracy of the personal data, for a period enabling Agentsia Intellect Ltd to verify the accuracy of the personal data;
• the processing is unlawful, but you do not wish your personal data to be erased, but only their use to be restricted;
• Agentsia Intellect Ltd no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defense of your legal claims;
• You have objected to the processing pending verification of whether the legitimate grounds of “Agentsia Intellect” OOD take precedence over your interests.

Right to portability

Art. 11. (1) You may at any time download the data that is stored and processed about you in connection with the use of the services of “Intellect Agency” Ltd by submitting a request via email.

Right to receive information

Art. 12. You may request that “Intellect Agency” Ltd inform you of all recipients to whom the personal data for which correction, deletion, or restriction of processing has been requested have been disclosed. “Intellect Agency” Ltd may refuse to provide this information if it would be impossible or would require disproportionately large effort.

Right to object

Art. 13. You may object at any time to the processing of personal data by “Intellect Agency” Ltd that relates to you, including if it is processed for the purposes of profiling or direct marketing.

Your rights in the event of a personal data security breach

Art. 14. (1) If “Intellect Agency” Ltd identifies a breach of the security of your personal data that may pose a high risk to your rights and freedoms, we will notify you without undue delay of the breach, as well as the measures that have been taken or are about to be taken.

(2) Agentsia Intellect Ltd is not obliged to notify you if:

• has taken appropriate technical and organizational protection measures with regard to the data affected by the security breach;
• has subsequently taken measures that ensure the breach will not result in a high risk to your rights;
• the notification would require disproportionate effort.

Persons to whom your personal data is provided

Art. 15. For the performance of translation and legalization services, your personal data is processed by sworn translators and editors before the Ministry of Foreign Affairs.

Other provisions

Art. 17. In the event of a violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Commission for Personal Data Protection, as follows:

1. Name: Commission for Personal Data Protection
2. Registered office and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Phone: 02 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg

Art. 18(1). When you assign "Intellect Agency" Ltd. to process personal data of a third party for the purposes of using the service, "Intellect Agency" Ltd. acts as a personal data processor.

(2). In the cases under para. 1, “Intellect Agency” Ltd acts solely on your instruction as a user of the service and only to the extent it can have control over the personal data that you process.

Advertising

At present, we do not use personal data for advertising purposes, nor do we provide personal data to other parties (personal data processors) for advertising purposes.

However, by confirming the request you agree that Agentsia "Intellect" OOD has the right to use the collected personal data for the following purposes:

• Including the user's evaluation and opinion in marketing research through electronic methods - via e-mail or messenger.
• Sending electronic messages about products, services and other promotional messages to all owned devices.
• Any other purposes related to direct marketing;
• Profiling and sending personalized advertising tailored to the user's preferences. Personalization is carried out based on an assessment of the user's behavioral data;
• Sending personalized commercial offers tailored to the user's behavior and preferences via email, mail or messenger. For this purpose, the user's consumption data based on their purchasing behavior, participation in promotional campaigns, and website usage may be subject to analysis and forecasting of the user's interests;
• Sending non-personalized advertising. Users will also receive information about current products, services, initiatives and other promotional messages.

When we process personal data for the purposes of direct marketing, the data subject has the right, free of charge and at any time, to object to the processing, including profiling, insofar as it is related to direct marketing, whether it is initial or further processing.