PRIVACY AND PERSONAL DATA PROTECTION POLICY
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NEXT CONSULT JSC
PRIVACY AND PERSONAL DATA PROTECTION POLICY
Valid from 25 May 2018
I. Introduction
Next Consult JSC (hereinafter “Next Consult”) respects the privacy of its customers and guarantees the protection of their personal data to the fullest extent possible. This Privacy and Personal Data Protection Policy (hereinafter referred to as the “Privacy Policy”) has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.
This Privacy Policy regulates the processing of personal data by individuals or representatives of legal entities of our current or potential customers as well as users of our website: www.next-consult.com (hereinafter the “Website”) in connection with the services provided by Next Consult, including the services provided through and available on the Website.
This Privacy Policy, including a cookies policy, sets out the rules for processing any personal data by Next Consult collected from and about our clients or users of the Website, including personal data provided to us. This Privacy Policy does not affect, limit or invalidate your rights under the Personal Data Protection Act (hereinafter “PDPA”) or any other relevant legislation.
If you have any questions or comments regarding this Privacy Policy, please contact us at: digital@next-consult.com
Please read carefully this Privacy Policy before browsing the Website or providing your Personal Data, whether digitally on the Website or on paper. Please note that by providing your Personal Data, you agree to the terms and conditions of this Privacy Policy. If you do not wish your personal data to be processed by Next Consult in the manner described in this Privacy Policy, please do not submit it. The provision of personal data on your behalf is voluntary, in order to enable the use of certain services provided by us and/or the use of the Website and/or the access to it. Please note that in some cases we will not be able to provide you with the requested service if you do not provide us with the necessary information. Please also note that in certain cases your consent to the processing of personal data may not be necessary if Next Consult refers to another legal framework, e.g. fulfilment of legal obligations under the current legislation.
II. Who processes and is responsible for your personal data?
Next Consult JSC (“Next Consult”) is a commercial company registered in the Commercial Register at the Registry Agency under UIC 206336732, which collects, processes and stores your personal data under the terms and conditions of this Privacy Policy. Next Consult is a controller of personal data under the Personal Data Protection Act (LPPD). You can contact us at the following mailing address:Head office: 22 Zlaten Rog Str., Floor 6, 1407 Sofia or by e-mail: digital@next-consult.com
III. Personal data categories processed by Next Consult
1. Next Consult is entitled to process the publicly available personal data and/or personal data provided by you. The main types of personal data processed are as follows:
• Personal identification regarding the response to your inquiry made through our website (such as name, phone, e-mail, company);
• Personal identification regarding participations in events and trainings organised by NEXT CONSULT (such as name, phone number, e-mail, company, position);
• Personal identification regarding the conclusion of a contract and the carrying out of our activities (including name, personal identification number, identity card number, passport number, residence, nationality, language of communication, etc.);
• Other relevant contact details (including postal and e-mail addresses, telephone and fax numbers, etc.);
• Financial information (bank account and others);
• Information about a representative (legal representative or proxy) of our customers – legal entity;
• Data from the communication between you and Next Consult, habits, preferences, your satisfaction with our services (use of services activity, complaints, requests, etc.);
• Information about website visits and browsing the website, including operations and browsing history of the website;
• Data obtained during the fulfilment of obligations deriving from normative and regulatory acts (i.e. data from inquiries, regulations, investigative bodies, notary, tax offices, court, bailiff, etc.).
• Data obtained by entering into a contract and/or performing contractual obligations (including name, address, phone number and/or e-mail address, etc.).
2. Next Consult is entitled to process data prepared and generated by our website’s Analysis Systems:
• Data about the electronic communication device used, the type of the device, the operating system, the IP address (anonymised), the location;
3. In order to ensure the optimal services delivery and the obligations arising from customers’ contracts, Next Consult is entitled to process any information available in public registers (including public database and data disclosed on the Internet) as well as information received from third parties regarding the implementation of legal provisions regarding customers.
4. Next Consult is entitled and obliged to verify the correctness of the personal data stored in the database and for this purpose may require from you to verify the personal data and, if necessary, to correct or verify the correctness of your data.
5. Various types of personal data may be processed individually or together.
IV. Objectives and legal framework for processing of personal data
1. Processing of personal data necessary for the conclusion or fulfilment of contracts with us or in connection with the contract conclusion preparation.
Next Consult processes your data for the following purposes:
• Personal identification when making an inquiry via the contact form at our website or via e-mail.
• Organisation and participation in events and trainings;
• Customer identification when entering into a new or changing an existing contract with us; explanations of the services used; performance of a contract.
• Proposals for signing contracts, sending pre-contractual information and draft contract;
• Performance of obligations arising from contracts concluded with customers or with a represented company, exercise of rights and ensuring the performance of contracts by our customers;
• Processing and response to customer claims/complaints/inquiries;
• Technical assistance for creating an account (s) and recovering a forgotten password for accessing electronic services for electronic invoices;
• Technical support and troubleshooting as well as solving any technical problems, either on-site and through remote access to the customer’s equipment;
• Payment of obligations, rescheduling of amounts due;
• Warranty and service;
2. In fulfilment of its legal obligations, Next Consult processes your data for the following purposes:
• Issuing of invoices;
• Carrying out tax and social security control by the respective competent authorities;
• Obligations stipulated in the Accountancy Act and the Tax and Social Insurance Procedural Code as well as other related legislation in connection with keeping proper and lawful accounting.
3. Next Consult processes the relevant data provided with the explicit written consent of the customer for the following purposes:
• For direct marketing of products and services;
V. Categories of third parties accessing and processing your personal data
• Transportation/courier companies, postal operators with a view to fulfilling our contractual obligations, sending correspondence and communications, in connection with contracts between us;
• Persons who, under the assignment of Next Consult, maintain the equipment and software used to process your personal data;
• Banks servicing payments made by you;
• Persons to whom Next Consult has assigned the performance of specific services or the obligations associated with services we owe to you;
• Persons performing consultancy services in various professional fields, such as lawyers, accountants, auditors, etc.;
• Bodies, institutions and individuals to which we are required to provide personal data under the current legislation.
VI. How long is your personal data stored?
The duration of time that your personal data is stored depends on the processing purposes for which it was collected:
1. Personal data processed for the purpose of concluding/changing and executing contracts between Next Consult and you as a customer or respectively the represented company – for the duration of the contract and until the final settlement of all financial relations between the parties. Next Consult is also entitled to store some of your personal data for a longer period of time until the expiration of the applicable limitation period as defined by the law for the purpose of protection in the event of any customer claims regarding the performance/termination of contracts with us as well as for a long term in the case of an already arisen legal dispute until its final settlement with a court/ arbitration decision entered into force;
2. Personal data processed for the purpose of issuing accounting/financial documents for the implementation of the tax and social security controls, as the invoices, debit and credit notes, delivery records, contracts for the provision of services/goods, etc. shall be kept at least 11 (eleven) years after the expiry of the limitation period for repayment of the public claim unless the applicable law provides for a longer period.
3. Personal data processed for direct marketing purposes – until the explicit withdrawal of the given consent for direct marketing or the receipt of an objection to the processing of personal data for direct marketing.
VII. Your rights in relation to the processing of your Personal Data
1. General rights
In connection with the processing of personal data, you can exercise the following rights at any time during the period of storage or processing of your personal data by submitting an application to the Next Consult postal address listed above or electronically via e-mail: digital@next-consult.com
You are entitled to request from Next Consult:
• a copy of your personal data and access to them at any time;
• to correct without undue delay your inaccurate personal data as well as data that are not up to date;
• your personal data in a form convenient to transfer to another personal data controller, or to require to do so without being impeded by ourselves (data transfer right);
• your personal data be deleted without undue delay when there are legal grounds for this;
• to limit the processing of your personal data, in which case your data will only be stored but not processed.
Our refusal to limit the data processing will be explicit only in writing, and we are obliged to motivate it for legitimate reasons.
You may also:
• withdraw your consent to the processing of your personal data at any time, with a separate request addressed to Next Consult, for consent-based data processing;
• disagree with the processing of your personal data;
• disagree with the automated data processing, including profiling;
• not be subject of a decision based solely on automated data processing involving profiling.
2. You have the right to appeal to the supervisory authority
You have the right to submit a complaint directly to the supervisory body, in this case to the Personal Data Protection Commission at the following postal address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia (www.cpdp.bg).
If you wish to file a complaint regarding the processing of your personal data by Next Consult, you can do this using the provided data controller’s contact details.
3. Automated decision making
The data controller does not use your personal data for automated decision making. If we intend to use your personal data for automated decision making, you have the right to be informed and therefore to receive information about the logic of any automated processing of personal data relating to you.
4. Disagreement with the use of personal data for direct marketing
You have the right to disagree with the future processing of your personal data for the purposes of direct marketing and advertising as well as the disclosure to third parties and the personal data use by third parties for the purposes of direct marketing and advertising by withdrawing your consent anytime. To do so, you should send an e-mail with the request to discontinue the use of your personal data for direct marketing data at: digital@next-consult.com
5. Can you refuse to provide personal data to Next Consult and what are the consequences?
In order to respond to the inquiry on our website or to sign a contract with you and/or to provide you with the requested products and/or services, and/or in accordance with our legal and consequent contractual obligations, Next Consult needs certain data allowing us to contact you, or identifying the contractual party, respectively the proxy, contact details and payment details regarding the obligations.
Failure to provide such information prevents us from responding to your inquiry or entering into a contract with you.
6. Personal data of children
We do not collect deliberately personal data of children under the age of 16 (sixteen). If we find out that we have collected personal data of a minor child under the age of 16 (sixteen), the necessary measures shall be taken to delete the personal data as soon as possible or to obtain the consent of the person bearing parental responsibility for the child.
VIII. Protection of your personal data
Next Consult applies organisational, physical, IT and other necessary measures to ensure the security and protection of your personal data and the monitoring of personal data processing.Among others, such security measures include the following activities:
• Next Consult applies requirements for processing, registration and storage of personal data with internal procedures, compliance with which is constantly monitored;
• Access to employees of Next Consult to personal data and the authorisation for personal data processing in the Next Consult database, depending on their duties;
• Next Consult applies confidentiality obligations for its employees;
• Access to the Next Consult office equipment and the computers of each employee is limited;
• We implement all the necessary organisational and technical measures provided for in the Law on protection of personal data and best practices of international standards;
• In order to ensure the maximum security in the processing, transmission and storage of your data, we may apply additional protection mechanisms such as encryption, pseudonymisation and others.
The security measures we apply are subject to constant improvement and adaptation to the latest technologies.
IX. Links to other websites
The Website may contain links/hyperlinks to other websites. We do not operate linked websites and do not approve the content, services and products of these websites. We advise you to use the linked websites carefully and with due attention to their content and terms of use. Next Consult is not responsible for the privacy policy or the content of such websites and we recommend you to review their privacy policies. However, as soon as Next Consult receives information about illegal activities or illegal information on these websites, Next Consult will take immediate action to remove the electronic links to them.
X. Cookies Policy
In order to ensure the usability of our website https://next-consult.com (hereinafter “the Website”) and to personalise your visits, we sometimes place small data files on your device, called cookies. This is a common practice of almost all global websites. This document provides you with detailed information about cookies and cookies policy.
What are cookies?
Cookies are small data files saved by your browser on your electronic device. They allow the identification of the electronic device used for browsing and also ensure the proper functionality of a website according to individual preferences of the user. This improves the functionality of the website. Cookies typically contain the website name, the end device storage time, and a unique number. In certain cases, cookies also allow users to personally identify themselves.How do we use cookies?
Cookies are used in order to adapt the Website’s content to user’s preferences and to optimise the usability of the Website. They are also used for anonymous statistics (on the user’s behaviour on the Website) with the purpose to improve the structure, design, appearance and content of the Website.
What types of cookies do we use?
Next Consult may also allow the use of third party cookies. These are cookies related to software products recording anonymous user statistics (Google Analytics, Facebook, Google Tag Manager, etc.).
Alternatively, third-party cookies could be associated with “social” buttons and plug-ins allowing website sharing and interaction with social media and networks. In order to ensure the proper functionality of these tools, the social media, such as Facebook, Twitter, Instagram, etc., may record cookies via the Website to interact with the user’s anonymous profile on a social network or add data to the collected information in a way and with objectives set out in their respective policies and websites.
Some videos displayed on our Website but provided by third parties, e.g. YouTube, may use cookies to collect anonymous information such as how the user has accessed a video, which videos he or she has watched, etc. We do not have access to or control over cookies used and provided by third parties. This Privacy Policy does not apply to the way a third party collects and treats such information. It is recommended to read carefully the relevant third-party policies in order to be aware of the practices applied.
Personal data, if any, that are collected by cookies can only be used to perform specific user-related functions on the Website.
How do you manage and/or delete cookies through the Website?
Most websites automatically accept cookies. However, if you do not want to accept them, you can disable cookies in your browser.Most web browsers allow cookies to be controlled through the browser settings. You can usually find these settings in the Options, Settings or Preferences menus. You can delete all the cookies already stored on your computer, and set up most browsers to completely block cookies.However, if you do so, you may have to manually set up some functions each time you visit a website, and it is possible that some services and features may not work properly. Unfortunately, in most cases, there is no universal option to disable cookies without limiting the functionality they add to the website. Keep in mind that blocking cookies will affect the website’s usability and functionality and may also cause malfunctions of this website.
How long do we store your data?
NEXT CONSULT does not store personal data, if any, collected by cookies. You can easily delete cookies from your personal computer or mobile device using your browser. The instructions for managing or deleting cookies can be found in the Help menu in your browser. You can choose to disable cookies or to receive a notification every time a new cookie is sent to your personal computer or mobile device. Please keep in mind that if you restrict certain types of cookies, this may affect our website’s usability and full functionality.Amendments to the Privacy PolicyWe may update our Privacy and Personal Data Protection Policy from time to time. In case of changes to the current Policy, a notice will be published on our website as well as the updated version of our Privacy Policy. All amendments and additions to the Privacy Policy will be applied only after publishing of the latest version available via our Website.