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Security policy

PERSONAL DATA PROCESSING AND PROTECTION POLICY


    Effective as of: 15.09.2021

    Last version: 15.09.2021


1. What is personal data?

Personal data is information that directly or indirectly identifies you as an individual and indirectly means when combined with other information such as your name, postal address, e-mail address, telephone number, etc.


2. How do we process your personal data?

We at Partners Place Ltd. with UIC 206634084 (the site administrator) will use your personal data solely for the purposes of fulfilling the contract for the provision of services to which you are a party using our site, as well as for our marketing bulletin.


We do not collect or process any more or other types of personal data than we need to fulfill that purpose.


We will only use the personal data as set out in this policy, unless you have given us your explicit consent to any other use of your personal data, such as through an explicit declaration of consent to send marketing communications.


3. Which of your personal data do we process?

In order to achieve the universal goal (on your part to find a job or find a contractor, and on our part to connect you to each other) we will process the following categories of personal data, which vary depending on which party to the service contract you are:


(1) names;

(2) e-mail;

(3) a brief description of your activity;

(4) profile picture;

(5) languages you speak;

(6) your location;

(7) your time zone;

(8) education;

(9) previous work experience;

(10) portfolio of completed projects;

(11) third-party opinions and ratings for you;

(12) category, subcategory and skills;


The listed categories of personal data are only those that you provide to us when making an application or offering a quote. We will not ask for any personal data from you other than those necessary to achieve the ultimate goal.


We may be required to process and store personal data on legal grounds and to achieve legal compliance, such as to prevent, establish or investigate a criminal offence, prevent loss, fraud or other financial abuse.


4. Using the Home page:


This Privacy Policy also applies to your use of our website with the following mechanics and characteristics related to the protection of personal data.


(1) Cookies Our Website uses cookies and other technologies to improve the user's performance and functioning of the Website, user-friendliness and security, as well as for advertising performance research purposes. Please see our cookie policy for more details.


(2) Third-party websites: For the convenience of our visitors, this portal contains links to various websites that are not connected, controlled or managed by us. The policies and procedures we describe here do not apply to these websites. We are not responsible for the security or protection of any data collected by these third parties. We advise you to contact these websites directly for information about their data protection policies.

5. To whom we share your personal data:

We will disclose your personal data only for the purposes and only to those third parties listed below – unless we have obtained from you additional consent to transfer personal data to other categories of third parties given elsewhere, such as by means of a declaration of consent for a specific purpose. We will take appropriate measures to ensure that your personal data is processed, protected and transferred in accordance with applicable law.


(1) External service providers:


Where necessary, we engage other companies and individuals to perform on our behalf certain tasks complementary to our services, such as to companies delivering our goods - postal operators, shipping companies, etc. We will only share or access such information to external service providers to the extent necessary for the relevant purposes. This information may not be used by them for any other purpose, in particular for their purposes or for third-party purposes. External suppliers are contractually obliged with us to respect the confidentiality of your personal data.


(2) Transformation of a commercial company and redemption of shares:


In connection with the conversion, restructuring, merger, sale or other transfer of assets, we will transfer information, including personal data, on a reasonable scale to the acquirer of those units or assets and as necessary for the Transfer of Ownership, provided that the receiving party agrees to treat your personal data in a manner consistent with the applicable data protection law.


(3) Public authorities:


We will disclose your personal data to public authorities where required by law. For example, we will grant the requests of courts, administrative and other public state or municipal authorities, which may include similar bodies of state or municipal authority.


We do not transfer your personal data or any information that may concern you outside the territory of the Republic of Bulgaria.


6. Processing of personal data of children:

We do not collect or process personal data of children under the age of 18. If we learn that a child's personal data has been accidentally collected, we will delete the data in question in due course. 


7. Processing of special categories of personal data ('sensitive' data):

We do not collect or process the so-called " special categories of personal data, namely: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying a natural person, health data or data on the sex life or sexual orientation of the natural person.


8. Security of your data:

We take the security of your personal data seriously. We apply the appropriate level of protection and for this purpose we have developed reasonable physical, electronic and technical procedures to protect the data we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed. Access to your personal data is only allowed to those employees, service providers or persons associated with us on the basis of the need for information for business purposes or who need it for the performance of their duties. In the event of a leak of data containing personal data, we will follow all applicable notification rules in such cases.


9. What are your legal rights?

As a data subject, you have specific legal rights related to the personal data we collect from you. This applies to all processing activities that we perform and undertake with your personal data and which are listed above. We respect your individual rights and will answer your questions adequately.


The list that follows contains information about your rights arising from applicable data protection laws:


  • Right to rectification: You have the right to rectification of the personal data concerning you. We make reasonable efforts to make sure that the personal data at our disposal and under our control, which are regularly processed, is accurate, complete, up-to-date and relevant, based on the latest available information.


  • Right to restriction: You have the right to restrict the processing of your personal data if:

- dispute the accuracy of your personal data for the period we need to verify their accuracy, 

- the processing is unlawful and you request restriction of processing instead of erasure of your personal data,

- we no longer need your personal data, but you require it for the establishment, exercise or protection of rights and legitimate interests, or 

- object to the processing pending verification that our legitimate grounds take precedence over yours.


  • Right of access: You have the right to ask us for information about the personal data about you that we hold, including information about what categories of personal data we have or control, what they are used for, where we received them, if not directly from you, and to whom they were disclosed, if applicable. You are entitled to a free copy of the personal data we hold about you. Under current laws, we reserve the right to impose a reasonable fee on any additional copy after the first one you may request.


  • Right to portability: At your request, we will transfer your personal data to another controller where technically feasible, provided that the processing is based on your consent or contractual obligation. Instead of receiving a copy of your personal data, you may request that we transfer it directly to another administrator designated by you.


  • Right to erasure: You have the right to erasure of your personal data if: 

- personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

- you have the right to object to further processing of your personal data (see below) and exercise this right to object to the processing;

- the processing is based on your consent, you withdraw this consent and there is no other legal basis for the processing;

- personal data have been processed unlawfully;


Unless processing is necessary for the following reasons:

- to comply with a legal obligation that requires processing by us;

- in particular, for archiving purposes in the public interest;

- for the establishment, exercise or protection of rights and legitimate interests.


  • Right to object: You may object at any time to the processing of your personal data in relation to your particular situation, provided that the processing is not based on your consent, but on our legitimate interests or those of a third party. In such a case, we terminate the processing of your personal data unless we prove that there are compelling legal grounds that take precedence over your interests, or for the establishment, exercise or protection of legal claims. If you object to the processing, please specify whether you wish to delete your personal data or restrict our processing.


  • Right to lodge a complaint: In case of an alleged violation of the laws applicable to the protection of personal data, you may lodge a complaint with the data protection supervisory authority in your country of residence or the place of the alleged breach. In the Republic of Bulgaria, this body is the Commission for Personal Data Protection.


More information needed to realize your rights:


  • Deadline: We will try to fulfill your request for the exercise of rights or a request for information from us concerning your personal data within 30 days, which may be extended for specific reasons related to the specific legal law or due to the complexity of your request.


  • Restriction of access: In certain situations, we may not be able to give you access to all or part of your personal data due to legal provisions. If we refuse your request for access, we will let you know the reason for this refusal.


  • Inability to identify: In some cases, we may not be able to verify your personal data based on the identifiers provided in your request. In such cases, where we cannot identify you as a data subject, we do not have the objective ability to comply with your request for the exercise of your legal rights as set out in this section, unless you provide us with additional information that will allow us to identify you.


  • Exercise of your legal rights: In order to exercise your legal rights, please contact us at the addresses specified at the end of this policy.


10. Storing your personal data:

In general, we will store the personal data you have provided to us for as long as we need it to perform the services to which you are a party, as well as for a longer period, to the extent required by the applicable regulations governing the requirements for accounting and control of the company's cash flows.


11. Changes to this policy:

We reserve the right to change our data protection practices and to update and amend this policy at any time. For this reason, we invite you to consult the policy on a regular basis. This data protection policy is up to date on the date of the "last revision", which is indicated at the top of this page.

12. Contact details:

The data of the personal data controller are Partners Place Ltd. with Unified Identification Code (UIC) 206634084, address: 18 Stefan Karadzha Street, Loznitsa, 7290, Bulgaria.


Please make your inquiries about data protection and any requests regarding the exercise of your legal rights on the email specified on the site.