Privacy policy

This Privacy Policy applies to personal data relating to individuals who are in business with Kuyumdjieva & Vitliemov law office (“Kuyumdjieva & Vitliemov”), individuals who contact Kuyumdjieva & Vitliemov, contacts representing legal entities in business with Kuyumdjieva & Vitliemov, as well as other contacts (hereafter referred to collectively as “Customers” or “you”).
This Privacy Policy is intended to inform you about what personal data Kuyumdjieva & Vitliemov collects, how Kuyumdjieva & Vitliemov uses such personal data and who has access to the data.
If you are unsure of how this Privacy Policy concerns you, please contact us for more information. Our contact information can be found near the end of this Policy.

1. Purpose and legal obligation
Kuyumdjieva & Vitliemov seeks to comply with all applicable privacy legislation and this Policy is based on the Act on Personal Data Protection of 4 January 2002, as subsequently amended (the “Data Protection Act”).

2. What is personal data?
Personal data within the meaning of this Policy is any data about a personally identified or a personally identifiable person, i.e. data that can be directly or indirectly attributed to a particular individual. Data which is not personally identifiable does not constitute personal data.

3. Customers’ Personal Data processed by Kuyumdjieva & Vitliemov
We collect and store various personal data about our Customers. Different types of personal data may be collected about you depending on whether you are in business with Kuyumdjieva & Vitliemov yourself or whether you represent a legal entity in business with Kuyumdjieva & Vitliemov.
When our Customer is an individual, Kuyumdjieva & Vitliemov collects the following data on the Customer:

• contact information, such as name, address or place of stay, phone number and email address;
• identification number;
• information from our communication with the Customer;
• bank account information;

When a Customer is a legal entity, Kuyumdjieva & Vitliemov collects specific information regarding the representatives of such parties, in particular:
• contact information, such as name, phone number and email address; and
• communication history.

Kuyumdjieva & Vitliemov may also obtain information regarding politically exposed persons within the meaning of the Act on Measures against Money Laundering of 27 March 2018, as subsequently amended (“Money Laundering Act”). Politically exposed persons are natural persons, domestic or foreign, who have been entrusted with prominent public functions, together with their immediate family and close associates.

In addition to the above data, Kuyumdjieva & Vitliemov may also collect and process other data with which Customers or representatives/contacts of Customers provide the Kuyumdjieva & Vitliemov themselves, as well as data that Kuyumdjieva & Vitliemov processes for its activities, including its main activities, which is legal services. The data is processed primarily in order to be able to fulfil formal and informal service agreements with our Customers and to perform any other duties resulting from our service to Customers, but also on the basis of our legitimate interests of ensuring that our Customers receive good service. Also, data may be processed on the basis of a legal obligation, irrespective of the services Kuyumdjieva & Vitliemov has undertaken to provide to its Customers, e.g. obligations relating to rules on money laundering or accounting laws.

As a rule, Kuyumdjieva & Vitliemov receives personal data directly from its Customers or Customers’ representatives. However, data may also come from third parties, such as public authorities, courts, service providers to Customers, counterparties and other lawyers. Personal data may also be collected online, from various websites, social media and databases. If personal data are received from a third party in other instances, Kuyumdjieva & Vitliemov will endeavour to notify its Customers thereof.

4. Personal data of individuals who contact Kuyumdjieva & Vitliemov and visit our website
When individuals contact our office, Kuyumdjieva & Vitliemov generally processes the individual’s contact data and communication history with Kuyumdjieva & Vitliemov.
When individuals visit Kuyumdjieva & Vitliemov’s website, we may process specified data which is collected via cookies. Kuyumdjieva & Vitliemov only uses necessary cookies, based on Kuyumdjieva & Vitliemov‘ legitimate interests. Non personally identifiable data is also collected on the website‘s traffic.

5. Sharing with third parties
Kuyumdjieva & Vitliemov may share your personal data with third parties, such as in connection with their contractual relationship with Kuyumdjieva & Vitliemov, or in relation to the legal services provided to you or the company which you represent. For example, data about you may be shared with a debt collector for the collection of debts or to other third parties, such as an external adviser or contractor, in connection with counsel given to you or the protection of your interests.
Your personal data may also be delivered to a third party to the extent permitted or required on the basis of applicable laws or rules, such as to public authorities, the courts, counterparties in a dispute, witnesses, partners of Customers or other invested parties, and in order to respond to legal measures such as a court order.

Also, personal data might be shared with third parties who supply us with information technology services and other services related to processing and which form part of Kuyumdjieva & Vitliemov’s activities.

6. How is the security of personal data ensured?
Kuyumdjieva & Vitliemov seeks to take appropriate technical and organizational measures to protect personal data with particular regard to their nature. These measures are intended to protect personal data against being lost or changed by accident and against unauthorized access, copying, use or dissemination. Examples of security measures taken by Kuyumdjieva & Vitliemov are access controls to Kuyumdjieva & Vitliemov’s systems as well as the use of operational logs.

7. Changes and corrections to personal data
It is important that the personal data processed by Kuyumdjieva & Vitliemov is both accurate and appropriate. Therefore, it is important that Kuyumdjieva & Vitliemov is notified of any changes that may occur to your personal data.
You have the right to have unreliable personal data about you corrected. Taking into account the purpose of the processing of your personal data, you also have the right to have incomplete personal data about you completed, including by submitting additional information.

8. Your rights regarding the personal data processed by Kuyumdjieva & Vitliemov
You have the right to obtain confirmation on whether we process personal data about you or not, and if so, you may request access to the data and how it is processed. You may also be entitled to a copy of the data. In certain circumstances, you may request from Kuyumdjieva & Vitliemov that we send data which you have provided us with yourself or that originates with you, directly to a third party.
Under certain circumstances, you may request that your personal data be deleted without delay, e.g. where retention of the data is no longer necessary in light of the purpose of the processing or because you have withdrawn your consent for the processing of the personal data and the processing is not based on any other legal basis. If the processing is based on your consent, you may at any time withdraw such consent.
If you do not want to have your data deleted, e.g. because you need it for your defence against a claim, but you nevertheless do not want it to be processed further by Kuyumdjieva & Vitliemov, you may request its processing to be limited.
If the processing of your personal data is based on legitimate interests of Kuyumdjieva & Vitliemov, you also have the right to object to such processing.
Your above rights are not absolute. Thus, laws may obligate Kuyumdjieva & Vitliemov to reject a request for deletion or access to data. In addition, Kuyumdjieva & Vitliemov may reject your request in consequence of Kuyumdjieva & Vitliemov’s rights, such as on the basis of intellectual property rights or the rights of other parties, such as to privacy, if Kuyumdjieva & Vitliemov considers these rights to prevail.
In case of a situation where Kuyumdjieva & Vitliemov cannot meet your request, Kuyumdjieva & Vitliemov will seek to explain why the request was rejected, subject to any limitations on the basis of legal obligation.

9. Inquiries and complaints to the Data Protection Authority
If you wish to exercise the rights described in Article 7-8 of this Policy, or if you have any questions regarding this Privacy Policy or how Kuyumdjieva & Vitliemov processes your personal data, please contact us, cf. Article 10 of this Policy.
If you disagree with Kuyumdjieva & Vitliemov’s processing of personal data, you may submit a communication to the Data Protection Authority (https://cpdp.bg).

10. Contact information
We have appointed a contact person to monitor compliance with this Privacy Policy. Below you can find such person’s contact information:
Stanislava Kuyumdjieva, stanislava.kuyumdjieva@skvlaw.eu,
+359 2 954 26 10.
Kuyumdjieva & Vitliemov’s contact information:
Kuyumdjieva & Vitliemov law office
7 Dobromir Hriz Street
1124 Sofia
Bulgaria

11. Revision
Kuyumdjieva & Vitliemov may from time to time change this privacy policy in accordance with changes to applicable laws or regulations or as a result of changes in the way Kuyumdjieva & Vitliemov processes personal data.
Any changes that may be made to this Policy will take effect after the updated version has been published on Kuyumdjieva & Vitliemov’s website.

This Privacy Policy was adopted on 25 May 2018.