- “Personal Data” means any information relating to an identified natural person or an identifiable natural person (“PERSONAL DATA SUBJECT”). An identifiable natural person is a person who can be identified, directly or indirectly, in particular by an identifier such as a name, an identification number, location data, an online identifier or by one or more characteristics specific to the physical, the physiological, genetic, psychic, mental, economic, cultural or social identity of that natural person.
- “Personal data processing” means any operation or set of operations performed on personal data or a set of personal data by automatic or other means such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use , disclosure by transmission, distribution or other way in which the data becomes available, arrangement or combination, restriction, erasure or destruction.
- “Personal data protection policy” (hereinafter referred to as “the Policy”), for the purposes of this document, means the rules for protection of personal data, which rules are in accordance with REGULATION (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “the Regulation”), as well as in accordance with the Personal Data Protection Act, and are applied by “LudiArs” Ltd., Unified Identification Code: 203376579.
- “Data Controller” means a natural or legal person, public body, agency or other structure that alone or jointly with others determines the purposes and means of processing personal data; where the purposes and means of this processing are determined by European Union law or the law of a Member State, the controller or the special criteria for its determination may be established in European Union law or in the law of a Member State;
- “Contact persons” – natural persons – managers/executive directors/representatives of legal entities – customers/counterparties of “LudiArs” Ltd.
- “Company Employees” – natural persons employed by “LudiArs” Ltd., who have entered into a civil or employment contract with that Company.
- INFORMATION about “LudiArs” Ltd.
- “LudiArs” Ltd., Unified Identification Code: 203376579, with registered office and management address: city of Sofia, 23 “Moskovska” Str. (hereinafter referred to as “LudiArs” or “the Company”), is a company registered in the Republic of Bulgaria, which is a personal data controller and personal data recipient, represented by its manager Daniel Slavchev Nikolov.
- “LudiArs” processes the personal data provided to it lawfully, in good faith and in a transparent manner with respect to the data subject in accordance with the principles and requirements of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “the Regulation”).
III. PERSONAL DATA CATEGORIES processed through the website https://ludiars.com
“LudiArs” processes the following “ordinary” personal data of natural persons – Users, namely: three names, e-mail address, telephone number, IP address, and in the case of a request for issuing an invoice – the Personal Identification Number and address.
- PURPOSES OF PERSONAL DATA PROCESSING
“LudiArs” processes the provided personal data for the purpose of:
– issuing of accounting documents for services provided by “LudiArs”,
– execution of concluded contracts between “LudiArs”, on the first side, and natural persons – Users, on the other side,
– sending informational electronic messages about current products/services offered by “LudiArs”;
– for the proper functioning of the website https://ludiars.com and for facilitating the search of services by the User.
- PROCESSING PERIOD
- “LudiArs” collects the personal data of natural persons – Users, for issuing accounting documents. To the extent that the personal data is contained in accounting documentation, “LudiArs” stores that data in accordance with the procedure and the retention periods stipulated by the Bulgarian legislation.
- “LudiArs” stores the personal data of Users as long as the latter keep their registered user profile active by purchasing at least 1 service within a calendar year and as long as those Users have the right to access the programs purchased by them, which are provided through the website https://ludiars.com.
- PROCESSING METHOD
- “LudiArs” stores the personal data provided to it on a technical (electronic) medium.
VII. GROUNDS FOR PROCESSING
“LudiArs” processes the personal data provided to it:
- a) in order to comply with its legal obligations;
- b) for the purposes of its legitimate interests, and
- c) for the execution of concluded contracts/execution of assigned work.
VIII. ACCESS TO PERSONAL DATA
The consultants and representatives of “LudiArs” have the right to access the personal data of Users, which right is subject to compliance with all the rules for personal data protection and confidentiality. Such right of access is also possessed by the accounting company, the IT support company and the lawyers, whose services “LudiArs” uses, as well as by third parties in the cases stipulated by law.
- PERSONAL DATA SUBJECTS rights
- The personal data subject has the right to obtain confirmation from “LudiArs” on whether personal data relating to him/her is being processed and, if that is case, to obtain access to the data and information regarding:
– the purposes of processing;
– what categories of personal data are processed;
– recipients to whom the data will be disclosed;
– the data retention period or criteria for its determination;
– the right to request rectification;
– the right to request deletion of personal data;
– the right to request restriction on the processing of his/her personal data;
– the right to data portability;
– the right of objection to such processing;
– the right to lodge a complaint with the Personal Data Protection Commission;
– the person who provided the data (this right applies only to the contact persons specified by the legal entity).
- RIGHT OF RECTIFICATION
The personal data subject has the right to ask “LudiArs” to correct his/her data, as well as to request the completion of incomplete personal data.
- RIGHT OF ERASURE
3.1. The personal data subject has the right to ask “LudiArs” to delete personal data related to him/her.
3.2. “LudiArs” will delete personal data related to the subject at the latter’s request when:
– the personal data are no longer necessary for the purposes for which they were collected or have been otherwise processed;
– the data subject withdraws his/her consent, in cases where the reason for processing the data is only this consent and when there is no other reason for their processing;
– the personal data were processed unlawfully;
– the personal data must be deleted in order to comply with a legal obligation under Union law or the law of a Member State that applies to the Data Controller;
3.3. When the data subject has requested erasure, “LudiArs” shall take all the necessary measures to notify the data controllers processing the personal data that the data subject has requested the erasure by those data controllers of all links, copies or replicas of that personal data.
- RIGHT TO RESTRICTION OF PROCESSING
4.1. The data subject has the right to request from “LudiArs” the restriction of processing when one of the following hypotheses is present:
- a) the accuracy of the personal data is contested by the data subject, for a period that allows “LudiArs” to verify the accuracy of the personal data;
- b) the processing is unlawful, but the data subject does not wish the personal data to be deleted, but instead requests the restriction of its use;
- c) “LudiArs” no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise or defense of legal claims;
- d) the data subject has objected to the processing pursuant to Art. 21, par. 1, of the Regulation pending verification of whether the legitimate grounds of the Data Controller prevail over the interests of the data subject.
4.2. In cases of restriction of data processing, personal data will be processed, with the exception of their storage, only with the consent of the data subject or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural person or for important reasons of public interest for the Union or a Member State.
4.3. “LudiArs” shall inform the subject who requested the restriction before the cancellation of that restriction of processing.
- RIGHT TO DATA PORTABILITY
5.1. The data subject has the right to receive the personal data concerning him/her and which data he/she has provided to the Data Controller in a structured, widely used and machine-readable format and also has the right to transfer such data to another data controller without hindrance from the Data Controller to whom the personal data has been provided in the event that:
– the processing is based on consent or a contractual obligation, and
– the processing is performed by automated means.
5.2. When exercising his/her right to data portability, the data subject has the right to obtain a direct transfer of personal data from one data controller to another, when that is technically feasible.
- RIGHT OF OBJECTION TO PROCESSING
6.1. In the cases where “LudiArs” processes personal data on the grounds of Art. 6, par. 1, letter “e” of the Regulation, namely: for the purposes of the legitimate interests of “LudiArs” or of a third party, the data subject has the right to object to the processing of personal data concerning him/her.
6.2. In such a case, “LudiArs” shall terminate the processing unless it proves that there are compelling legal grounds for the processing that take precedence over the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
- MANNER OF EXERCISING THE DATA SUBJECT’S RIGHTS
- The personal data subject must direct his/her requests, inquiries and objections to “LudiArs” at e-mail address: firstname.lastname@example.org.
- Requests/inquiries/objections of the data subject may be addressed in writing to “LudiArs” at the provided contact address: city of Sofia, 23 “Moskovska” Str.
- Requests/inquiries/objections can also be sent electronically to e-mail address: email@example.com.
- Requests/inquiries/objections shall be made personally by the individual or by a person expressly authorized by him/her through a notarized power of attorney.
- Requests/inquiries/objections must contain: the name, address and other identification data of the respective natural person; description of the request; preferred form of providing the information – in writing, verbally or by electronic means; signature, date of submission of the application and correspondence address/correspondence e-mail.
- When the application is submitted by an authorized person, the notarized power of attorney must also be attached to the application.
- “LudiArs” shall take a decision on the requests, inquiries and objections of the personal data subjects within a time period of 1 /one/ month from the receipt of the request, and within the same period the Company shall notify the data subject of the result by sending a message to the contact e-mail address, provided by the data subject.
- “LudiArs” shall provide the information requested by the data subject in writing, verbally or electronically by an e-mail message, depending on the method explicitly indicated by the data subject.
- “LudiArs” shall communicate any rectification, erasure or restriction of processing to any recipient to whom the personal data has been disclosed, unless this is impossible or requires a disproportionately large effort. “LudiArs” shall inform the data subject about those recipients if the data subject requests this.
- “LudiArs” shall provide the requested information to the data subject free of charge.
- “LudiArs” shall have the right to demand the payment of a fee by the data subject or to refuse to take action on the request when the requests of a data subject are manifestly ungrounded or excessive due to their repetition.
- Where “LudiArs” has reasonable concerns regarding the identity of the natural person submitting an application, it may request the provision of additional information necessary to confirm the identity of that data subject.
- With regard to requests/inquiries/objections, “LudiArs” shall keeps a special register, which shall briefly note the content of the request/inquiry/objection, the identity of the data subject who sent the application, the date of receipt of the requests/inquiries/objections, the date of the decision made on the latter by “LudiArs”, the date of notification, the summary of the content of the decision.
- Every year “LudiArs” shall perform a periodic review regarding the need to process personal data, respectively regarding the need to delete them.
- The data subject can contact “LudiArs” at the following e-mail (electronic mail) address: firstname.lastname@example.org or at phone Nr. +359 888 011811.
- Final provisions
The provisions of the Regulation and the Bulgarian legislation shall apply to all cases not covered by this Policy.