DECLARATION – PRIVACY NOTICE
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 (General Data Protection Regulation, GDPR) entered into force on 25 May 2018.
To this end, as of 20.10.20023, the companies BESTSELF Ltd., with UIC 205673796 and “COGNITIVA 23” Ltd., with UIC 206273619 introduce the following changes to their Privacy Policies:
According to the selected program and services, a Personal Data Administrator may be either the company BESTSELF Ltd., with UIC 205673796 or the company “COGNITIVA 23” Ltd., with UIC 206273619, both registered in accordance with the laws of the Republic of Bulgaria. Both companies process personal data as joint Administrators under an agreement therebetween.
DETAILS OF ADMINISTRATORS:
1. BESTSELF Ltd., with UIC 205673796;
CONTACT DATA:
• Management address: city of Sofia, Postal code 1797, Izgrev district, 30 Tsarigradsko shose Blvd., block Balkan, entrance D, floor 7, apt. 18;
• Phone: +359 887 474 090
• Email: info@bestself-therapy.com
• Web: https://bestself-therapy.com
• Manager of BESTSELF Ltd. and of “COGNITIVA 23” Ltd.: Daniela Stefanova Dimitrova
2. “COGNITIVA 23” Ltd., with UIC 206273619
• Management address: city of Sofia, Postal code 1000, Sredets district, 163А “Georgi S. Rakovski” Str., apt. 7;
• Phone: +359 887 474 090
• Email: info@bestself-therapy.com
• Web: https://bestself-therapy.com
• Manager of BESTSELF Ltd. and of “COGNITIVA 23” Ltd.: Daniela Stefanova Dimitrova
THE PERSONAL DATA WE COLLECT AND PROCESS ARE:
- of the physical identity type: name, address, phone number, email address, age, date of birth, place of residence, native language, professional qualification, occupation;
- other – bank account information for payments by bank transfer;
- health status data, including of diagnoses, to the extent necessary for participation in programs and provision of services;
We do not process special categories of data relating to race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning the sexual life or sexual orientation.
SOURCE:
Data is obtained from the personal data subject or from a parent/guardian in respect of a child.
We declare that the personal data we collect will be used for the following purposes only: participation in programs and provision of services by the companies BESTSELF Ltd., with UIC 205673796 and/or “COGNITIVA 23” Ltd., with UIC 206273619.
THE GROUNDS THAT ENTITLE US TO PROCESS YOUR DATA ARE:
- participation in programs and provision of services in relation to accounting requirements and tax legislation – Article 6, paragraph 1, p. “b” of the GDPR;
- legitimate interest of the companies BESTSELF Ltd., with UIC 205673796 and/or “COGNITIVA 23” Ltd., with UIC 206273619, for example, in the event of any claims that may be made against us – Article 6, paragraph 1, p. “b” of the GDPR.
- consent provided for receiving information, video, audio and photo recording.
ALL LEGITIMATE INTERESTS PURSUED BY US OR BY ANY THIRD PARTIES WORKING FOR US ARE AS FOLLOWS:
Carrying out the companies’ business activities and providing services under current programs.
THE FOLLOWING ORGANISATIONS/PERSONS WILL RECEIVE YOUR PERSONAL DATA: the National Revenue Agency, other state and municipal authorities, such as the State Agency for Child Protection, etc., to whom they are provided under specific and clear legal obligations.
WILL YOU FORWARD AND SHARE MY PERSONAL DATA WITH OTHER ORGANISATIONS OR PERSONS?
We will not provide your data to third parties, nor will we transfer it in order to gain any benefit.
CONSENT:
You provide us with your personal data or that of your child, as mentioned above, for processing, as we could not provide our services without it. Your explicit consent is not necessary.
By accepting this Declaration – Privacy Notice, you give us permission to process your personal data only for the purposes we have identified.
Your explicit consent to the processing of your personal data or that of your child is necessary only in cases where it serves to obtain information about our other services and programs, such as receiving information, newsletters, conducting surveys, video, audio and photo recording, etc.
The consent may be withdrawn at any time in writing by a free form letter sent to the email address specified above, unless there are other grounds which oblige or entitle us to continue to process an individual’s personal data.
If you find it difficult to exercise your rights, you may contact us at any time using the following contact details for assistance, including for obtaining a relevant form.
TRANSFER OF PERSONAL DATA TO A COUNTRY OUTSIDE THE EU OR TO AN INTERNATIONAL ORGANISATION:
The companies BESTSELF Ltd., with UIC 205673796 and/or “COGNITIVA 23” Ltd., with UIC 206273619 do not intend to transfer your personal data to third parties outside the EU.
Where web-based software is used to implement any of the programs, each of the providers of such software, as well as the communication channels through which individuals provide personal data, such as Viber, WhatsApp, etc., have declared compliance with the requirements of the General Data Protection Regulation and have provided the required information to personal data subjects.
DATA RETENTION PERIOD
The companies BESTSELF Ltd., with UIC 205673796 and/or “COGNITIVA 23” Ltd., with UIC 206273619 will store your personal data in accordance with the statutory time frames, but not more than 5 years after the date of termination of your relationship with these companies, and in the case of consent provided for processing of personal data – until the withdrawal of this consent, unless the legitimate interest of the companies specifies a longer retention period.
YOUR RIGHTS AS A PERSONAL DATA SUBJECT ARE AS FOLLOWS:
Your rights as a personal data subject are as follows:
- You have the following rights at all times while we are storing or processing your personal data:
you are entitled to request a copy of your personal data and to have access to your personal data; - you are entitled to request a correction of your personal data without any undue delay, as well as of data that is no longer up to date;
- you are entitled to have your personal data deleted without any undue delay based on any of the following grounds:
- the personal data is no longer necessary for the purposes for which it has been collected;
- where the processing is unlawful;
- where the personal data must be deleted in order to comply with a legal obligation under the law of the EU or any Member State that is applicable to us as a personal data administrator;
We may refuse to delete your personal data for the following reasons: - to comply with a legal obligation on our part or to carry out a task in the public interest,
- for reasons of public interest in the field of the public health;
- if it is necessary for us to use your personal data for a new purpose not covered by this Declaration – Privacy Notice, we will provide you with a new Declaration – Privacy Notice and, where and when necessary, we will require your prior consent to the new processing.
All of the above requests will be forwarded if there are any third parties (recipients) processing your personal data.
You can exercise the same rights if you are a parent or a guardian in relation to your children.
YOU HAVE THE RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY
You have the right to file a complaint directly to the supervisory authority when you consider that an infringement has been committed, the competent authority being the Commission for Personal Data Protection, address: city of Sofia 1592, 2 “Tsvetan Lazarov” Str. (www.cpdp.bg).
In the event that you wish to file a complaint as regards the processing of your personal data through us, you may do so at the contact details of the companies BESTSELF Ltd., with UIC 205673796 and/or “COGNITIVA 23” Ltd., with UIC 206273619.
YOU CAN EXERCISE ALL OF YOUR RIGHTS LISTED ABOVE IN RELATION TO PROCESSING OF YOUR PERSONAL DATA BY SENDING A FREE FORM EMAIL WITH YOUR REQUEST TO THE EMAIL ADDRESS PROVIDED FOR CONTACT WITH THE COMPANIES BESTSELF Ltd., WITH UIC 205673796 AND/OR “COGNITIVA 23” Ltd., WITH UIC 206273619.
IN CASE YOU STILL HAVE DIFFICULTIES, YOU CAN ASK FOR ASSISTANCE IN EXERCISING YOUR RIGHTS AT THE CONTACT DETAILS OF THE COMPANIES BESTSELF Ltd., WITH UIC 205673796 AND/OR “COGNITIVA 23” Ltd., WITH UIC 206273619.
