ACCOUNTING SERVICES BULGARIA Ltd. ensures utmost protection of its clients’ personal data processed in connection with the services provided by the company.

This Privacy Policy has been drafted on the basis of the current Bulgarian legislation in the field of personal data protection and of Regulation (EU) 2016/679.

All amendments and supplements to this Privacy Policy will be applied after the updated content is published on our website www.accountingservices.bg. This Privacy Policy applies to your personal data if you are a natural person or a representative of a legal person who is a client of ACCOUNTING SERVICES BULGARIA Ltd. This Policy explains what personal information we process when providing our services, for what purposes will we use it, and what are your rights as a personal data subject.

Who processes and bears responsibility for your personal data?

ACCOUNTING SERVICES BULGARIA Ltd. is a trade company registered in the Commercial Register to the Registry Agency under UIC 202441262, which collects, processes and stores your personal data under the terms and conditions of this Privacy Policy. ACCOUNTING SERVICES BULGARIA Ltd. is a personal data controller within the meaning of the Law on Personal Data Protection (LPDP).

You can contact us at our registered address:

1000 Sofia, 5, Dobrudzha Str., Tel./Fax: +359 2 981 89 95 or by completing the electronic contact form on our website: http://www.accountingservices.bg/bg/contact-us/

1. What data do we process, for what purposes and on what legal grounds?

Depending on the specific purposes, ACCOUNTING SERVICES BULGARIA Ltd. processes the following data, either alone or in combination.

1.1 Data categories

A) Data provided by you that is necessary for identification and for fulfilment of

the contractual obligations of ACCOUNTING SERVICES BULGARIA Ltd. and of the client:

• three names, Personal Number or personal number of a foreign citizen, number and expiry date of an identity card or passport, address, phone number, e-mail address for contact with you or with contact persons specified by you;
• three names, Personal Number, number and expiry date of an identity card or passport, address, phone number, e-mail address and other data of your attorney, employee, or any other person referred to in the document with which you have authorized them to represent you before ACCOUNTING SERVICES BULGARIA Ltd. in connection with the execution of the contract.
• any data collected on payment made to ACCOUNTING SERVICES BULGARIA Ltd.

B) Data prepared and generated by ACCOUNTING SERVICES BULGARIA Ltd. in the course of providing our services:

• contract number and the like;
• data necessary for the drawing up of invoices, value of services used; information on the method of payment, payments made and due; information on changes in the use of the services, restrictions and recovery of services;

• IP address used when visiting our website;

• information on the nature and content of contractual relations, as well as any other information relevant to the contractual relations, including letters sent to an electronic mail, information on your requests for problem solving, complaints, applications and other feedback which we receive from you;

1.2. Purposes and legal grounds for the processing of personal data:

 A) Data processing which is necessary for the conclusion or execution of the contract. ACCOUNTING SERVICES BULGARIA Ltd. processes your data for the following purposes:

• To identify the client when: entering into a new or amending an existing contract for accounting and/or consulting or other business services, paying charges and sending correspondence.
• To update your personal data and or information in connection with services provided under contract;
• To draw up offers for the conclusion of contracts, to send a courier shipment with pre-contractual information and a draft contract;
• To pay bills, to reschedule the payment of amounts due;
• To prepare preliminary offers based on inquiries made by the client for the provision of services by ACCOUNTING SERVICES BULGARIA Ltd. and those referred to at www.accountingservices.bg;
• To carry out processing by the persons we have entrusted with this task;

B) In performance of its statutory obligations, ACCOUNTING SERVICES BULGARIA Ltd. processes your data for the following purposes:

• To draw up offers for the conclusion of contracts and the signing of contracts outside our office, to send a courier shipment with pre-contractual information and a draft contract, etc.;
• To provide information on the client and on the services used by them on inquiry/request/inspection by a competent authority;
• To issue invoices;
• For the exercise of taxation and social security control by the competent authorities;

C) ACCOUNTING SERVICES BULGARIA Ltd. also processes your data for the purposes of the following legitimate (lawful) interests of ours: legal procedures relating to the exercise of the rights arising from the

services provided by us; opening of bank accounts of the client at its request, establishment of trade companies at the client’s request, powers of attorney for representation of the client before various institutions in connection with the objectives and the fulfilment of the objectives of our contractual terms with the client, handling and preparation of staff records of the client’s employees, payment of remunerations to the client’s employees by bank transfer, ordering the payment of the client’s liabilities to suppliers and state institutions by bank transfer, drawing up of contracts at the client’s request, drawing up of powers of attorney at the client’s request.

2. Categories of third parties who are granted access to and process your personal data

2.1.    Processors who, on the basis of a contract signed with ACCOUNTING SERVICES BULGARIA Ltd., process your personal data on behalf of ACCOUNTING SERVICES BULGARIA Ltd. or have a direct/indirect access to your personal data, could be:

• Transport/courier companies with a view to the fulfilment of our contract obligations to deliver contracts on paper, equipment and the like;
• Persons who have been assigned by ACCOUNTING SERVICES BULGARIA Ltd. with the task to maintain equipment and software used for the processing of your personal data;
• Persons providing services for maintenance of terminals, insofar as the same store personal data;
• Agencies that collect unpaid client obligations.
• Subcontractors providing services related to the fulfilment of our contractual obligations, technical assistance for the installation and/or maintenance of equipment and the like;
• Banks that service the payments made by you;
• The bodies of the National Revenue Agency and the National Social Security Institute in connection with the conduct of inspections and audits of the client’s activities which ACCOUNTING SERVICES BULGARIA Ltd. prepares in connection with our contractual relations with the client.
• Persons providing services on organizing, storing, indexing and destruction of archives on paper and/or on electronic media;
• Persons providing consulting services in different spheres related to our activity.

2.2.      Other personal data controllers to whom ACCOUNTING SERVICES BULGARIA Ltd. provides your personal data and who process your data on their own grounds and in their own name:

• The competent authorities which, by virtue of a regulatory act, have the power to require from ACCOUNTING SERVICES BULGARIA Ltd. to provide information, among which personal data, such as - National Revenue Agency (NRA), National Statistical Institute (NSI),  National Social Security Institute (NSSI), Labour Inspectorate, Combating Organized Crime Directorate General, National Investigation Service, any Bulgarian court or a court of another state and other supervisory/regulatory authorities;
• To ensure an adequate protection of the data of the company and of its customers, we apply all the necessary organizational and technical measures provided for in the Law on Personal Data Protection as well as the best practices laid down in international standards.

3. How long do we store your personal data?

3.1. The duration of storage of your personal data is dependent on the purpose of the processing for which they were collected:

• Personal data processed with the purpose of concluding/amending and executing a contract shall be kept for the period of validity of the contract and up to the final settlement of all financial relations between the parties;
• Personal data processed for the purpose of issuing accounting/financial documents for the implementation of the tax and social security control, such as but not limited to invoices, debit and credit notes, delivery and acceptance reports, service contracts shall be kept for at least 5 years after the expiry of the limitation period for the repayment of the public receivable unless the applicable legislation provides for a longer period.
• Employment records of the client’s staff until the expiry of the contract period with the client or at the client’s request;
• ACCOUNTING SERVICES BULGARIA Ltd. may store some of your personal data for a longer period until the expiry of the relevant limitation period for repayment with the purpose of protecting against any claims of the clients in connection with the execution/termination of a contract, and for a longer period in the event of an already occurred legal dispute in connection with the above matter until its final settlement with an enforced court/arbitration decision.

4. What are your rights in relation to the processing of personal data by ACCOUNTING SERVICES BULGARIA Ltd.?

As our client, and as regards your personal data, you have the following rights:

4.1.    To gain access to your personal data and any information relating to them. You can request from ACCOUNTING SERVICES BULGARIA Ltd. information whether and for what purposes do we process your personal data by filing a written application with the content referred to in Article 29 LPDP;

4.2.    To require your personal data to be erased, rectified or blocked where such data are inaccurate or should be supplemented, or their processing does not meet the requirements of the legislation;

 4.3.    To object before ACCOUNTING SERVICES BULGARIA Ltd. at any time to the processing of personal data in the presence of legal grounds for this;

 4.4.    To withdraw your consent to the processing of personal data, but only where the processing is based solely on your consent;

 4.5. To submit a complaint to the Commission for Personal Data Protection, if you consider that your rights have been affected.

5. Can you refuse to provide personal data to ACCOUNTING SERVICES BULGARIA Ltd. and what are the consequences of such refusal:

To conclude a contract with you and to provide you with the requested services in accordance with our statutory obligations, ACCOUNTING SERVICES BULGARIA Ltd. is in need of certain data. Your failure to provide the following data precludes ACCOUNTING SERVICES BULGARIA Ltd. from signing a contract for services/goods with you:

• three names, Personal Number or personal number of a foreign citizen, number and expiry date of an identity card or passport, address, phone number, e-mail address for contact with you or with contact persons specified by you;
• three names, Personal Number or personal number of a foreign citizen, number and expiry date of an identity card or passport, address, phone number, e-mail address for contact with your attorney specified by you and referred to in the document with which you have authorized them to represent you before ACCOUNTING SERVICES BULGARIA Ltd.;
• any data collected on payment made to ACCOUNTING SERVICES BULGARIA Ltd.;
• mailing address.

6. Cookie Policy.

To enhance its performance, the website electronic platform uses a type of data files called "cookies". What are the cookies and why are they used? Cookies are small text files for temporary storage of information on the user actions,  preferences or any other activity performed during a website visit. They are stored on the PC or mobile device used by the user for a certain period of time depending on their type. Cookies make the use of a website easier as they save the users the need to re-enter their preferences every time they visit the website or move from one page to another. Cookies enable the smooth operation of the website, help it detect irregularities and find opportunities to optimize the ways in which it provides information to and communicates with users.

Types of cookies - the website may use one or several of the following types of cookies depending on their degree of necessity:

• System cookies - These are cookies without which the operation of the website is impossible or is placed at high risk. Such are cookies used to navigate the website, to save completed information when switching between different steps as well as to log in or register. System cookies also ensure security control of the connection and protection against unwanted external interventions. This type of cookies is often defined as temporary or session cookies as they are temporarily stored and disappear after closing  the browser session.
• Functionality cookies - this category of cookies serves to facilitate the user in his use of the website and to ensure compliance with the user preferences. Functionality cookies include cookies used to identify the device, to save preferences concerning language, font size, etc. This type of cookies can be stored for a longer time on the device, they can be used in more than one browser session and are called permanent cookies.
• Third-party cookies for performance, analyses and advertising - Cookies for analysis serve for the collection of statistical information on the basis of which general conclusions can be drawn and recommendations can be made concerning the website performance with respect to the objectives of users as well as with a view to marketing and advertising purposes. Such statistics include the number of users of the page, most visited pages, sources of the visit, time spent on the page, errors occurred, etc. These cookies allow to collect anonymous information about the way in which users navigate the website and the difficulties that they may experience. To be more precise, the website uses the established analytical tools of Google Analytics and Core Metrics. Deactivation of cookies. As a user, you have the opportunity to control the use of cookies, to delete the cookies stored on your device, and to deactivate the future use of cookies. Detailed instructions for the different browsers and operating systems you can find at http://www.aboutcookies.org/. Please note that the blocking of cookies will affect the way in which the website works and may result in impaired functioning of the website.

• Links - the website may include links to other websites that are beyond our control. We cannot be held responsible for the protection of personal data or for the content of these websites, but we offer these links to help our visitors find more information on specific subjects. This policy was last updated in April 2018 and was introduced in connection with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.