Last update as at: 15 October 2018

 

Thank you for visiting our Website. This Policy aims to inform you about the way we process your personal data collected through this site and about your rights in this regard.

 

  1. Personal Data Controller

AFA OOD, having UIC 030278596 and AFA Consultants OOD, having UIC 121813481 (hereinafter referred to as AFA) manage jointly the following website: www.afa.bg and are controllers of the personal data, collected and processed through this website.

In order to be as useful as possible through its Website, in certain cases AFA processes personal data of the Website’s users and as such is a controller of personal data within the meaning of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).

The security of your data is an important part of AFA’s internal policies. As Controller, AFA considers with the utmost priority the issues of the protection of your personal data collected during your visit on our Website and the processes of their processing and storage in accordance with the legal requirements.

 

  1. Contact Us

You may contact AFA in one of the following ways:

  • In writing, at the following address: 38 Oborishte Str., Oborishte Region, 1504, Sofia;
  • Telephone number: (+359 2) 943 37 00 or(+359 2) 425 02 00;
  • Fax number:(+359 2) 943 37 07;
  • By e-mail address: office@afa.bg;
  • Via Website: afa.bg.

 

  1. Personal Data We Collect for You through the Website. Purposes and Legal Bases for Their Processing

Using the information on our Website does not imply the provision of any personal data on your part. The page contains the following functionalities, by using which it may be possible for AFA to collect and process your personal data:

 

3.1. Subscribing to the AFA Newsletter

If you choose, you can register to receive the AFA newsletter containing useful information about changes to tax, banking, accounting and social security legislation by providing us with your e-mail address. In this case, your personal data will be processed by AFA for the purposes of receiving our newsletter.

The legal basis for processing of these personal data is your explicit, voluntary consent, which you have provided by registering yourself for this service.

AFA shall process your personal data until you have objected to this processing or unsubscribe from receiving our newsletter further at the specified hereinabove e-mail address.

 

3.2. Sending an Inquiry

The personal data collected and processed by AFA through the option for asking questions on the Website E‑mail Us are: your names, e-mail address, place of work, telephone number and other data that you have decided to provide us with in your inquiry.

Personal data, which you have decided to provide us, may be also collected if you send an inquiry to the e-mail address of one of our contact persons listed in the Contacts section of the Website.

Your personal data are collected and processed:

  • In order to be replied to the inquiry you sent us. The legal basis for processing your personal data in this case is your explicit, voluntary consent, which we assume you have given, by sending us the inquiry.

AFA shall process your personal data only for the time required to prepare and send a reply to your inquiry and within 3 months of our last correspondence with you, unless you become our client, in which case the terms of the agreement/ contract for provision of services signed between us will apply regarding the processing of your personal data.

  • We can also use these data for direct marketing purposes - to inform you about the services provided by AFA or to invite you to take part in trainings, conferences and other professional events organized by us. In this case, the legal basis for processing your personal data is the protection of AFA’s legitimate interests in presenting and popularizing its services.

AFA shall process your personal data for this purpose until you object to it or until you opt-out from receiving our direct marketing communications at the following e-mail address: office@afa.bg.

 

3.3. Participation in Trainings

You can register for a training organized by AFA through the Training section of the Website. In this case, AFA shall process the personal data you have provided (e.g., name, surname, e-mail address or contact telephone number, as well as name of the company you are working for) for the following purposes:

  • To register you for participation in the training chosen by you. The legal basis for processing of your personal data in this case is your explicit, voluntary consent, which we assume that you have provided us with by submitting the registration form for participation in the training. AFA shall process your personal data for this purpose until the training is completed or until you withdraw your consent for this processing by sending an email to the following e-mail address: office@afa.bg. Your personal data will then be erased;
  • For the purposes of maintaining of a database for future use for sending invitations to trainings, conferences and other professional events, organized by us. In this case, the legal basis for processing of your personal data is to protect AFA's legitimate interests in presenting and promoting its services. AFA shall process your personal data for this purpose until you have objected to it or until you opt-out of receiving our invitations for trainings to the specified hereinabove e-mail address.

 

3.4. Applying for a Job/ Summer Internship

You can apply for a job/ summer internship with AFA through the Careers and internships section of the Website by sending your short resume (CV) to the following e-mail address: office@afa.bg. In these cases, AFA shall process the personal data you have provided (e.g., image from a photograph, three names, date of birth, education, labour activity, address, e-mail address, telephone number and any other information you have decided to include in your resume) for the following purposes:

  • To offer you an appropriate job position in AFA, if such one is present currently;
  • For the purposes of maintaining a database for the future use and selection of candidates in view of employment.

In this case, the legal basis for processing of your personal data is to take steps at your request with a view to the possible conclusion of a contract. AFA shall process your personal data provided in your CV for a term of 6 months from their receipt, unless you explicitly consent to the remaining of the personal data available for processing in the database for a longer term.

 

3.5. Other Collected Data

In addition to the personal data specified hereinabove as collected by AFA, the following data may additionally be processed upon usage of certain features of the Website:

  • Log files, in connection with security, technical maintenance & development issues - logs are files that record events in and interactions between systems and/or between users and a specific system;
  • Cookies and other tracking technologies that collect information from you when interacting with our Website in order for us to improve its performance and functionality.

Cookies are small text files that can be saved on your computer or mobile device when you visit a particular website. The cookie will help the website or other websites to recognize your device the next time you visit it/ them. Web beacons or other similar files can do the same. In this policy, we use the term cookies to name all the files that collect information in this way.

More about the cookies as well as about the ways to opt out of using cookies on your device can be found in our Cookies Policy

 

  1. Personal Data Processing in the Course of Provision of Audit & Consulting Services

In the course of the performed independent financial audit and the provision of other consulting services, AFA as personal data controller receives from its clients and processes the personal data of a wide range of data subjects:

  • legal representatives and/or proxies of the clients – assignors under the contracts concluded by AFA;
  • stockholders, shareholders and members of the management bodies of the clients or of companies affiliated thereto and persons, related to the ones indicated herein, including beneficial owners pursuant to the Measures Against Money Laundering Act;
  • contact persons of the clients, other employees and persons, providing services to the clients under civil contracts;
  • natural persons – contractors of the clients;
  • natural persons, legal representatives, proxies, members of the management bodies of legal entities – contractors of AFA’s clients.

On the basis of an assessment made by the Controller, it is concluded that the provision in person of information about the processing of personal data to the subjects specified hereunder, will involve a disproportionate amount of effort and, in some cases, will be impossible. In this regard, AFA publishes on its Website Written information for subjects whose personal data are processed in the course of the provision of audit and consulting services.

 

  1. Consequences upon Non-Provision of Personal Data

The provision of data by you is entirely voluntary. In case you do not want to provide your personal data, you shall not be able to receive the services you wish - you shall not receive our newsletter, respectively we shall not be able to respond to your inquiry, to register you for participation in training or to offer you a job position.

 

  1. Sharing of Your Personal Data

AFA may provide access to your personal data to the following categories of recipients:

  • State bodies/ authorities to which we are required to provide personal data by law;
  • A service provider for the maintenance of this Website.

 

  1. Your Rights

In relation to the processing of your personal data by AFA, you have various rights for the protection of your interests. All rights listed hereinbelow (except for the right of complaint to a supervisory authority) can be exercised by submitting a request to AFA using the contact details provided in Section 2 Contact Us hereinabove. AFA shall make the necessary efforts to satisfy your request without any undue delay.

 

7.1. Right to Access

It is your basic right at any time to obtain confirmation from AFA whether your personal data are being processed, as well as access to the data processed and information on the purposes of the processing, the categories of personal data being processed, the recipients of your personal data, the term of processing, the presence of automated decision making and your rights in connection with the processing.

 

7.2. Right to Rectification

When you believe that the personal data processed for you are inaccurate, you are entitled to request from AFA their correction and also to request that your incomplete personal data be completed.

 

7.3. Right to Erasure

As a data subject, whose personal data are being processed by AFA, you are entitled to request their erasure in the following cases:

  • The personal data are no longer necessary for the purposes for which they have been collected and processed;
  • Withdrawal of your consent on the basis of which your personal data have been processed;
  • Your personal data have been processed unlawfully;
  • You have objected to the processing of your data and there are no legal grounds for the processing that have a priority;
  • The personal data must be erased in order to comply with the legislation of the European Union or the Republic of Bulgaria.

 

7.4. Right to Restriction of Processing

Another right of yours, in relation to the processing of your personal data by AFA is to require, as long as the legal requirements are met, AFA to restrict the processing of your data in the following cases:

  • You dispute the accuracy of the personal data - for a term that allows AFA to verify the accuracy of your data;
  • The processing of your personal data is illegal, but you do not want to erase your personal data but instead to restrict their use;
  • AFA no longer needs your personal data for the purposes specified herein, but you require that they be retained by AFA by limiting their processing for the purposes of establishing, exercise or defense of legal claims on your part.

 

7.5. Right to Objection against the Personal Data Processing

As far as your personal data are subject to processing by AFA, you have the right to object at any time to such processing. In this case, AFA will discontinue the processing of your personal data unless there is any other legal basis for their further processing, such as compliance with legal requirements or other legitimate interests that require continuation of the processing.

 

7.6. Right to Withdrawal of Your Consent

The processing of your personal data by AFA, which is based on your explicit consent, may be terminated by withdrawal of your consent. This right of yours has immediate effect but does not affect the lawfulness of the personal data processing of your data, carried out until the withdrawal of your consent.

 

7.7. Right to Data Portability

You are entitled to receive a copy of the personal data you have provided to AFA, including, where possible, in electronic form. When the processing of your data is based on consent or a contractual obligation and is carried out in an automated manner, you can address a request to AFA to receive your personal data in a structured, widely used, machine-readable format. In this context, you can also ask AFA to transfer these personal data directly to another personal data controller at your instruction.

 

7.8. Right to Complaint with Supervisory Authority

If you believe that your personal data are being processed unlawfully or your rights in relation to them have been violated, you have the right to lodge a complaint with the competent Bulgarian supervisory authority - the Commission for Personal Data Protection (CPDP). You can contact the CPDP by using the following contact details, specified hereinbelow:

Address: 2 Prof. Tsvetan Lazarov Blvd., 1592, Sofia;

Telephone number: 02/ 91-53-518;

E-mail address: kzld@cpdp.bg.

 

  1. Amendment of These Privacy Policy

AFA may periodically change this Privacy Policy to comply with legislative changes or specific practices and policies applied by AFA. When we make such changes, we also change the date of the last update listed at the beginning of this Policy, so that you can familiarize yourselves with the current conditions for the processing of your personal data.