Stoeva Tchompalov & Znepolski is committed to protecting the personal data of all people we deal with. This Notice sets out important information about how we may collect and use your personal data.

Scope

This Notice applies to all persons whose personal data we collect and use. This includes individuals in the categories below or any individuals who work for any of the following:

• our clients;
• 3rd parties;
• experts;
• witnesses;
• 3rd party solicitors;
• individuals who are involved in contracts and transactions we are working on (for example other businesses/individuals our clients are contracting or working with);
• our business contacts;
• service providers (for example IT service providers); and/or
• governmental bodies and/or certification bodies (for example Sofia Bar Association).

What Personal Data Do We Collect?

Personal data means information which identifies you and relates to you as an individual. Stoeva Tchompalov & Znepolski will collect, store and use your personal data for a variety of reasons in connection with your relationship with us. We have set out the main categories of personal data which we process on a day to day basis:

• personal contact information (including your name, home address, personal telephone number(s) and/or personal e-mail address);
• policy number/policy inception date;
• claim number;
• bank account details;
• loss details/claim and/or personal circumstances;
• vulnerabilities;
• online identifiers;
• date of birth;
• gender; and/or
• information gathered through correspondence with us (for example, in relation to parties and/or third parties to a claim).

The personal data that we collect will depend on your relationship with us.

The list set out above is not exhaustive and there may be other personal data which Stoeva Tchompalov & Znepolski collects, stores and uses in the context of the relationship. We will update this Notice from time to time to reflect any notable changes in the categories of data which are processed.

The personal data which we process will be collected from a number of sources including (but not limited to) the individuals in the categories listed in Section “Scope” above or any individuals who work for any of these categories.

How Do We Use Your Personal Data?

Stoeva Tchompalov & Znepolski uses your personal data for a variety of purposes in order to provide our services as a law firm.

We may use your personal data if:

• you have provided your consent to such use; or
• it is necessary for the performance of a contract with you; or
• necessary in connection with a legal and/or regulatory obligation or as otherwise required or authorised by law; or
• we consider such use of your personal data as not detrimental to you, within your reasonable expectations, having a minimal impact on your privacy, and necessary to fulfil our legitimate interests.

We have set out below the main purposes for which your personal data may be processed which include (but are not limited to):

• providing our services, such as:
  • managing court or legal proceedings;
  • providing legal advice;
  • advising on and negotiating legal contracts;
• complying with our legal obligations or making disclosures to government, regulatory or other public bodies where the disclosure is appropriate and/or permitted by law;
• providing access to our files for audit, review or other quality assurance checks by our clients, auditors, professional advisors, governmental bodies and/or certification bodies;
• day to day operations of our business. For this we may use third party service providers (for example accountancy services and/or IT service providers).

Again, this list is not exhaustive and Stoeva Tchompalov & Znepolski may undertake additional processing of personal data in line with the purposes set out above. We will update this Notice from time to time to reflect any notable changes to the purposes for which your personal data is processed.

What Special Categories of Personal Data Do We Process?

Certain categories of data are considered "special categories of data" and are subject to additional safeguards. The special categories of personal data which we process may relate to:

• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• trade union membership;
• genetic and/or biometric data;
• physical and mental health; and/or
• sex life and/or sexual orientation.

When Do We Share Personal Data?

Stoeva Tchompalov & Znepolski may share your personal data with other parties in certain circumstances and where it is necessary to achieve the purposes detailed above or to comply with a legal and/or regulatory obligation, or otherwise in pursuit of its legitimate business interests. Such other parties may include (without limitation) the individuals in the categories listed in Section “Scope” above or any individuals who work for any of these categories.

In all cases, your personal data is shared under the terms of a written agreement between Stoeva Tchompalov & Znepolski and the third party, which includes appropriate security measures to protect the personal data in line with this Notice and also our obligations or as permitted by applicable law.

Your personal information may be transferred outside of the European Economic Area ('EEA'). For example, this may be in relation to an international legal claim or transaction, or where we are sharing information with our colleagues or third-party service providers who operate outside of the EEA.

In all cases, where personal data is transferred to a country which is deemed not to have the same level of protection for personal data as the home country in the EEA, Stoeva Tchompalov & Znepolski will put in place written transfer agreements to protect the personal data. In the case of a transfer of personal data from a country within the EEA to a country outside of the EEA, these transfer agreements will incorporate the standard contractual clauses approved by the European Commission.

For How Long Will My Personal Data Be Retained?

Stoeva Tchompalov & Znepolski policy is to retain personal data only for as long as is needed to fulfil the purpose(s) for which it was collected, or otherwise required under applicable Bulgarian laws and/or business continuity purposes.

Unless there is any other valid legal, regulatory, client or business reason to retain it beyond that timescale, all matter files will usually be destroyed at approximately 5 years after the matter has been closed.

What Are My Rights in Relation to My Personal Data?

Stoeva Tchompalov & Znepolski will always seek to process your personal data in accordance with our obligations, our rights and your rights.

You will not be subject to decisions based solely on automated data processing without your prior consent.

In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format.

You have a separate right of access to your personal data processed by Stoeva Tchompalov & Znepolski. You may be asked for information to confirm your identity and/or assist us to locate the data you are seeking as part of our response to your request.

if you are an individual located in the EU and you consider that our processing of your personal data violates data protection law or your rights have been violated by other means, you are entitled to file a complaint with the competent supervisory authority. The competent supervisory authority in Bulgaria is the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, tel. +3592/91-53-518, e-mail: kzld@cpdp.bg, web-site: www.cpdp.bg.

Where Can I Get Further Information?

If you have any questions about this Notice, want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, want to delete all or any part of it or to object to the processing on legitimate grounds, please contact us by email on office@stzlaw.eu or by post to:

Stoeva Tchompalov & Znepolski
111, Evlogi and Hristo Georgievi Blvd., fl. 1
Sofia 1504
Bulgaria

Last updated: May 2018