EmGroup Accounting

Mon-Sat

info@emgroup.bg

Privacy policy

Mandatory information on the rights of individuals with regard to the protection of personal data:

Information about the company processing your data:

Name: And End EM Accounting Group Ltd.

UIC/BULSTAT: 206399775

Registered office and address of management: Sofia, 1000, 21 Lavelle str., floor 1, ap.2

Address for correspondence: Sofia, 1000, 21 Lavelle str., floor 1, ap.2

Phone: 00359879063336

E-mail: info@emgroup.bg

Website: https://www.emgroup.bg/

Information on the competent data protection supervisory authority

Name: Commission for Personal Data Protection

Registered office and address of management: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov 2

Address for correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov 2

Phone: 02 915 3 518

Website: www.cpdp.bg

“E and M Accounting Group” LTD (hereinafter referred to as the Company) carries out its activities in accordance with the  Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. This information aims to inform you about all aspects of the processing of your personal data by the Company and the rights you have in connection with this processing.

Grounds for collecting, processing and storing your personal data

Art. 1. The Company collects and processes your personal data in connection with the use of https://www.emgroup.bg/ and the conclusion of contracts with  the company on the basis of Art. 6, para 1, Regulation (EU) 2016/679 (GDPR),and in particular on the following grounds:

  • Explicit consent received by you as a customer;
  • Fulfillment of the Company’s obligations under a contract with you;
  • Compliance with a legal obligation that applies to the Company;
  • For the purposes of the legitimate interests of the Company or of a third party;

Objectives and principles for the collection, processing and storage of your personal data

Art. 2. (1) We collect and process the personal data that you provide to us in connection with the use of our services and conclusion of a contract with the Company, including for the following purposes:

  • creating an account and providing full functionality in the use of our services;
  • conclusion and performance of a distance contract;
  • individualisation of a party to the contract;
  • accounting purposes;
  • statistical purposes;
  • protection of information security;
  • ensuring the performance of the contract for the provision of the service concerned;
  • sending a newsletter at your request;

(2) We observe the following principles when processing your personal data:

  • legality, good faith and transparency;
  • restriction of processing purposes;
  • accountability with the purposes of processing and minimising the data collected;
  • accuracy and timeliness of the data;
  • restriction of storage in order to achieve the objectives;
  • integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.

(3) In the processing and storage of personal data, the Company may process and store the personal data in order to protect its following legitimate interests:

  • fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.

What types of personal data does our company collect, process and store

Art. 3. (1) The Company shall perform the following operations with the personal data provided by you for the following purposes:

  • Filling in an online form for ordering a service or registering a user on the site and fulfilling a distance purchase contract – the purpose of this operation is to obtain the minimum necessary personal data for the performance of the respective service and providing contact details. Registration, creation of an account and filling in an online request are not a mandatory step in the provision of the service and it is accessible to a significant extent and without the creation of an account.
    Conclusion of the impact assessment: Based on the impact assessment carried out, the operation “Filling in an online form for ordering a service or registering a user on the site and performing a distance purchase contract” is permissible and provides sufficient guarantees to protect the rights and legitimate interests of the data subjects in accordance with gdpr requirements.
  • Conclusion and execution of a commercial transaction with a client or partner – the purpose of this operation is to conclude and execute a contract with a trading partner or client and its administration.
  • Sending a newsletter – the purpose of this operation is to administer the process of sending newsletters to customers who have stated that they wish to receive.
  • Exercising the right to refuse or make a claim – the purpose of this operation is to administer the process of exercising the right of withdrawal or claim by the client.

(2) The Company shall process the following categories of personal data and information for the following purposes and on the following grounds:

  • Your individualizing data (e-mail, name, etc.)
    • Purpose for which the data are collected: 1) Making contact with the user and sending information to him, 2) to provide a service chosen by the customer, as well as 3) to send a newsletter.
    • Reason for processing your personal data – By accepting the general terms and conditions and registering the site or filling in an online form for the provision of a service or when concluding a written contract, a contractual relationship is created between the Company and you on which we process your personal data – Art. 6, para 1, b. (b) GDPR.  Al. 1, b. (a) GDPR.
  • Delivery data (names, telephone, address, etc.)
    • Purpose for which the data are collected: Fulfillment of obligations of the Company under a contract provision of a service.
    • Reason for processing your personal data – By accepting the general terms and conditions and filling in the form for providing a service, or when concluding a written contract, a contractual relationship is created between the Company and you on which we process your personal data – Art. 6, para 1, b. (b) GDPR.
  • Additional data provided by you – If you want to supplement your account, you can fill in the name, surname, phone number.
    • Purpose for which the data is collected: Supplement user information in their user account.
    • Grounds for data processing: You have given explicit consent to the processing of his/her personal data for one or more specific purposes – 6, para 1, b. (a) of the GDPR at the time of registration on the site or filling in an online request form.

(3) The Company does not collect or process personal data that relate to the following:

  • racial or ethnic origin;
  • political, religious or philosophical beliefs or trade union membership;
  • genetic and biometric data, health data or data on sexual life or sexual orientation.

(4) The personal data have been collected by the Company from the persons to whom they relate.

(5)  The Company does not perform automated data decision-making.

Art. 4. (1) The Company shall perform the following operations with the services provided by you, as legal representatives or proxies of legal entities- trading partners, personal data for the following purposes:

  • Conclusion and execution of a commercial transaction: For the conclusion and execution of a commercial transaction with a commercial company, we process only the full names of the legal representative or the person authorized by the company. Conclusion of the impact assessment: Given the small volume of natural persons whose data are processed and given the limited volume of personal data being collected, an impact assessment is not necessary for this operation.

(2)  The personal data are collected by the Company from the persons to whom they also refer from the Commercial Register to the Registry Agency.

(3)  The Company does not perform automated data decision-making.

Art. 5. The Company may use the so-called cookies for the purpose of providing full functionality of the website, improving the user experience, statistical purposes, facilitated access, etc., which you agree to through the use of our website. You can control and/or delete cookies at any time through the settings of the browser you use. Cookies do not constitute personal data and are not used to identify visitors and users of the website.

Shelf life of your personal data

Art. 6. (1) The Company shall keep your personal data for no longer than the existence of your account on the website.

(2)  The Company processes your personal data, which you provided when placing an order without registration on our website, until the completion of the order, unless you have given your explicit consent when placing the order to process your data for the purposes of improving the service, providing recommended content for you, individual conditions, promotions, as well as for statistical purposes.

(3)  The Company stores your personal data provided in connection with online requests made for a period of 5 years for the purpose of protecting the legal interests of the Company in legal or administrative disputes with users of the website.

(4)  The Company notifies you in case the data retention period is necessary to be extended in order to fulfill a legal obligation or in view of the legitimate interests of the Company or otherwise.

(5)  The Company stores the personal data that it needs to keep under the applicable legislation for the relevant period of time, which may exceed the duration of your profile on the site or until the order is completed.

Art. 7. The Company stores the personal data of the legal representatives of its trading partners for the duration of the contract, for compliance with the legitimate interests and legal obligations of the Company, and this period may exceed the term of the concluded contract.

Transfer of your personal data for processing

Art. 8. (1) The Company may, at its sole discretion, transfer some or all of your personal data to processors for the performance of the processing purposes with which you have agreed, subject to the requirements of Regulation (EU) 2016/679 (GDPR).

(2) The Company shall notify you in case of intention to transfer some or all of your personal data to third countries or international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawal of consent to the processing of your personal data

Art. 9. (1) If you do not wish the personal data provided by you to be processed for marketing purposes and receiving a newsletter, you may at any time withdraw your consent to processing by filling in the form for withdrawal of consent in Appendix 1 or by a free text request and sending it to us by email.

(2)  Once we have received your request, we will send you the email you have indicated for receiving newsletters and advertisements, a letter with detailed instructions for your verification as a recipient of newsletters and subject to the personal data for which withdrawal of consent has been requested.

(3)  The withdrawal of consent does not affect the lawfulness of the processing of personal data that the Company has carried out so far.

Right of access

Art. 10. (1) You have the right to request and receive from the Company confirmation whether personal data related to you are being processed by sending a request in free text by email.

(2)  You have the right to access the data relating to you as well as the information relating to the collection, processing and storage of your personal data.

(3)  Once we have received your request, we will send you the email you used to register or place orders on our website with detailed instructions for your verification as a data subject to which access has been requested.

(4)  After carrying out the verification pursuant to para 3, the Company shall provide you, upon request, with a copy of the processed personal data relating to you in electronic or other appropriate form.

(5)  The provision of access to the data is free of charge, but the Company reserves the right to impose an administrative fee in case of repeated or excessive requests.

Right to rectification or replenishment

Art. 11. (1) You may at any time correct or fill in inaccurate or incomplete personal data relating to you.

(2)  You may correct or fill in inaccurate or incomplete personal data relating to you directly through your website account or by requesting to the Company by email using the form in Appendix 4 or by free text request.

Right to erasure (“to be forgotten”)

Art. 12. (1) You have the right to request from the Company the erasure of some or all of the personal data relating to you, and the Company has the obligation to delete them without undue delay when there are any of the following grounds:

  • personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • You withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;
  • You object to the processing of personal data relating to you, including for direct marketing purposes, and there are no legitimate grounds for the processing that prevail;
  • personal data have been processed unlawfully;
  • personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Company;
  • personal data have been collected in connection with the provision of information society services.

(2)  The Company is not obliged to delete the personal data if it stores and processes them:

  • the exercise of the right to freedom of expression and information;
  • to comply with a legal obligation requiring processing provided for in EU law or the law of the Member State applicable to the Company or for the performance of a task in the public interest or in the exercise of official powers conferred on it;
  • for reasons of public interest in the field of public health;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
  • the establishment, exercise or defence of legal claims.

(3)  In order to exercise your right to be forgotten, you need to send by email a request for deletion of your personal data that the Company processes by filling in the form in Appendix 2 or by a free text request, after which the Company will send to the email you have used to register or place orders on the website a letter with detailed instructions for your verification as a user of the site and subject of the personal data,  request for erasure.

(4)  Once we have verified the identity of the person making the request and the person to whom the data relate in accordance with the instructions sent to you, we will delete all data we process about you in accordance with para. 3.

(5)  If there is an order you have placed that is under processing, the earliest time you can request to be “forgotten” is when the order is successfully completed.

Right to restriction

Art. 13. You have the right to require the Company to restrict the processing of the data related to you by sending us a request in free text by email when:

  • dispute the accuracy of the personal data for a period that allows the Company to verify the accuracy of the personal data;
  • processing is unlawful, but you do not want the personal data to be deleted, only to limit their use;
  • The Company no longer needs personal data for the purposes of processing, but you require them for the establishment, exercise or protection of your legal claims;
  • You have objected to the processing pending verification of whether the legitimate grounds of the Company take precedence over your interests.

(2)  Once we have received your request, we will send you to the email you have used to register or place orders on the website, a letter with detailed instructions for your verification as a website user and data subject for which a request to restrict processing has been made.

(3)  After performing the verification pursuant to paragraph 2, the Company will stop processing your data, but will not remove the posts you have made on the website, if any.

Right to portability

Art. 14. (1) If you have given consent to the processing of your personal data or the processing is necessary for the performance of the contract with the Company, or if your data is processed in an automated manner, you may:

  • to ask the Company to provide you with your personal data in a readable format and transfer it to another Controller;
  • to ask the Company to directly transfer your personal data to an administrator designated by you, where technically feasible.

(2)  You can exercise the right to portability by emailing us a completed form according to Appendix 3 or a free text request, after which the Company will send to the email you have used to register or place orders on the website a letter with detailed instructions for your verification as a user of the website and subject of the personal data,  portability request.

(3)  After performing the verification pursuant to para 2, the Company sent to the email specified by you the data it processes for you in XML format.

Right to receive information

Art. 15. You may ask the Company to inform you about all recipients to whom personal data for which rectification, erasure or restriction of processing has been requested have been disclosed.

Right to object

Art. 16. You may object at any time to the processing of personal data by the Company that relate to it, including if it is processed for profiling or direct marketing purposes.

Your rights in case of a breach of the security of your personal data

Art. 17. (1) If the Company finds a breach of the security of your personal data that may pose a high risk to your rights and freedoms, it shall notify you without undue delay of the breach, as well as of the measures taken or to be taken.

(2)  The Company is not obliged to notify you if:

  • has taken appropriate technical and organisational protection measures in respect of data affected by the security breach;
  • has subsequently taken measures to ensure that the infringement does not result in a high risk to your rights;
  • notification would require disproportionate efforts.

Persons to whom your personal data is provided

Art. 18. (1) For the purposes of processing your personal data and providing the service in its full functionality and in view of your interests, the Company may provide the data to the following data processors:

Processor Purpose of the processing of personal data

Radoslav Kazan Service Provision

(2)  Processors comply with all legality and security requirements for the processing and storage of your personal data.

Art. 19. The Company does not transfer your data to third countries.

Art. 20. In case of violation of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection as follows:

Name: Commission for Personal Data Protection.

Registered office and address of management: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Address for correspondence: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Phone: 02 915 3 518

Website: www.cpdp.bg

Art. 21. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are optional and you can make your requests in any form that contains a statement to do so and identifies you as the holder of the data.

Art. 22. If the consent relates to a transfer, the Company describes the possible risks for the transfer of the data to third countries in the absence of a decision on adequate protection and appropriate remedies.

Annex No 1

Form of withdrawal of consent for processing purposes

Your name*: …………………….

Your email you have used on the website*: …………………….

Feedback (e-mail)*: ……………………………..

Until

Name: …………………….

UIC/BULSTAT: …………………….

Registered office and address of management: …………………….

Address for correspondence: …………………….

Phone: …………………….

E-mail: …………………….

Website: …………………….

I hereby withdraw my consent to the processing of the personal data provided by me for the purpose of receiving a newsletter, advertisements or other marketing materials, and am aware of the conditions for withdrawal of consent in accordance with the Mandatory Information on the Rights of Individuals with Personal Data Protection on the Website.

In case of violation of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection as follows:

Name: Commission for Personal Data Protection.

Registered office and address of management: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Address for correspondence: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Phone: 02 915 3 518

Website: www.cpdp.bg

Annex No 2

Request “to be forgotten” – to delete the personal data related to me

Your name*: …………………….

Your email with which you have registered or used for orders on our website*: …………………….

Feedback (e-mail)*: ……………………………..

Until

Name: …………………….

UIC/BULSTAT: …………………….

Registered office and address of management: …………………….

Address for correspondence: …………………….

Phone: …………………….

E-mail: …………………….

Website: …………………….

I ask that all personal data you collect, process and store provided by me or by third parties that are related to me, according to the specified identification, be deleted from your databases.

I declare that I know that some or all of my personal data may continue to be processed and stored by the Company for the purposes of fulfilling its legal obligations.

In case of violation of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection as follows:

Name: Commission for Personal Data Protection.

Registered office and address of management: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Address for correspondence: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Phone: 02 915 3 518

Website: www.cpdp.bg

Annex No 3

Request for portability of personal data

Your name*: …………………….

Your email with which you have registered or used for orders on our website*: …………………….

Feedback (e-mail)*: ……………………………..

Until

Name: …………………….

UIC/BULSTAT: …………………….

Registered office and address of management: …………………….

Address for correspondence: …………………….

Phone: …………………….

E-mail: …………………….

Website: …………………….

I ask that all personal data relating to me that is collected, processed and stored in your databases be sent in XML format to:

e-mail: …………………….

Controller – receiving the data: …………………….

Name: …………………….

Identification number (UIC, BULSTAT, reg. number in the KN): …………………….

E-mail: …………………….

In case of violation of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection as follows:

Name: Commission for Personal Data Protection.

Registered office and address of management: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Address for correspondence: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Phone: 02 915 3 518

Website: www.cpdp.bg

Annex No 4

Request for correction of data

Your name*: …………………….

Your email with which you have registered or used for orders on our website*: …………………….

Feedback (e-mail)*: ……………………………..

Until

Name: …………………….

UIC/BULSTAT: …………………….

Registered office and address of management: …………………….

Address for correspondence: …………………….

Phone: …………………….

E-mail: …………………….

Website: …………………….

I ask that the following personal data that you collect, process and store provided by me or by third parties that are related to me be corrected as follows:

Data to be corrected:

…………………………………………..

Please correct them as follows:

…………………………………………..

In case of violation of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection as follows:

Name: Commission for Personal Data Protection.

Registered office and address of management: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Address for correspondence: 1592 Sofia Blvd. “Prof. Dr.Sc.(Econ. 2 Tsvetan Lazarov Str.

Phone: 02 915 3 518

Website: www.cpdp.bg

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