Privacy Policy
This Privacy Policy addresses issues related to the protection of your personal data and their processing (the “Policy”) when visiting the website http://www.lukaev.eu (the “Website”) and using the services I provide. If you would like to know more on this topic, you can contact me at the contacts below.
In addition to this Policy, you can also take a look at the Cookie Policy and the Terms and Conditions of use of the Website published on the Website.
I. About me
The administrator of personal data according to this Policy is by Emil Kostadinov Lukaev, attorney-at-law, registered with the Sofia Bar Association under No. 1500666310, BULSTAT No. 177879686, VAT No. BG177879686, address at: 1113 Sofia, Region Iztok, 15G, Tintyava Str., Bulgaria, e-mail address: emil@lukaev.eu.
II. Information you can find in this Policy
This Privacy Policy will provide you with information as regards to what I collect and process the personal data provided, including:
» What personal data I collect;
» What is the purpose of their collection;
» For how long I will retain the personal data provided;
» With whom I share personal data;
» How I notify you of changes to this Policy;
» What are your rights regarding the personal data provided.
III. What is personal data?
Any information and data that can identify an individual directly or indirectly.
For example, indirect identification may be achieved by your telephone number. In this case I would need to combine it with another identifier about you to establish your identity, for example, a combination of names and a mobile phone number.
Direct identification is achieved when you provide a unique identifier, such as PIN. Personal data may also be automatically generated unique identifiers (e.g., your IP address) that can be used to indirectly identify you as an individual user, including through the installation of cookies on your end device.
IV. What personal data I do collect about you?
In order to provide more effective access to the Website for offering my services, I collect the following information about you:
» Technical data that is automatically sent to me when you use the Website – IP address, information about the device from which you visit the Website;
» Cookies – to identify your browser or device, including through the creation of individual automatically generated numbers by third-party service providers (Google Analytics) by means which the specific user can be identified;
» Personal data concerning your physical and social identity (name, address, role and office in the legal entity you represent or for which you are listed as the contact person) and contact details that you may provide to me within your e-mail messages addressed or via the contact form on the Website.
The processing of personal data includes the collection, storage, destruction, transmission, rectification, updating, erasure, disposal and all other actions that are carried out with your personal data.
V. On what grounds (why) I process personal data about you?
The legal grounds for collecting and using your personal data will depend on the specific context in which I collect it. In each case, I will only process the personal data for which you have explicitly authorised me.
Only technical information and personal data related to your visit to the Website will be processed.
The main reason for collecting and using your personal data is to make you familiar with my services and to fulfil my contractual obligations with you (i.e. to enable me to provide you with the service which you have assigned me). I will also use your personal data where it is in pursuit of our legitimate interests, but only where those interests are not overridden by your interests in relation to the protection of your personal data or your other rights and freedoms.
In some cases, I may have a legal obligation (legal grounds) to collect personal data from you or I may need to process it or share it with others to protect your interests or to fulfill my obligations in relation to the legal services assigned to me.
If I ask you to provide personal data to comply with a legal requirement or to enter into a contract with you, I will notify you of the circumstances and let you know whether or not the provision of personal data is mandatory and also explain the possible consequences of refusing to provide personal data.
Also, if I collect and use your personal data pursuant to my legitimate interests (or those of a third party), I will inform you what those legitimate interests are.
VI. How I obtain your personal data? How I process your personal data?
To present the services available on the Website, I process (collect) the technical data provided by you in the following ways:
» By visiting the Website to use my services;
» Via my contact form available on the Website or by sending an e-mail message to the e-mail address indicated on my Website which contains personal data about you or a third party;
» By using online identifiers to collect information about IP addresses, cookie data, operating system and browser type.
VII. How long do I store and process your data before I destroy it?
I will retain your personal information for no longer than is necessary to fulfill the purposes described in this Policy. Depending on the basis on which I process your personal data, the retention period varies.
Your personal data is stored by me for a period of 5 (five) years from the termination of our contractual relationship, if I process the personal data for the performance of contractual obligations to you. After the expiry of this period, and if there is no legal basis for the continued retention of your personal data, the information about you shall be destroyed and your personal data permanently deleted from my system.
Your personal data contained in accounting records, financial statements and documents for tax control, audit and subsequent financial inspections shall be stored for a period of 10 (ten) years as from January 1 of the year following the year to which they relate in accordance with the requirements of the Accounting Act and the Tax and Social Security Procedural Code.
All other media of accounting information shall be kept for a period of 3 (three) years as from January 1 of the year following the year to which they relate in accordance with the requirements of the Accounting Act.
Your personal data collected through the provision of your explicit consent to the use of my “cookies” is stored for a maximum period of 2 (two) years from the date of your consent, depending on the type of cookies concerned.
VIII. Are there other cases where I can share your personal data?
Your personal data is provided to third parties in the following cases:
» At the request of the individual who has provided the data;
» At the request of competent authorities in accordance with the legislation in force in the Republic of Bulgaria and the European Union.
IX. Use of “cookies”
My Website uses “cookies”. Cookies are small text files that are stored on your computer when you visit my Website.
In the event that you access this website at another time, your browser sends the contents of the cookies back to the respective provider and thus allows the re-identification of the end device. Reading cookies allows us to improve your experience and optimize my Website and make it easier for you to use it.
You can learn more about the “cookies” I use here.
X. What are your rights regarding the personal data provided?
Pursuant to the Bulgarian and European law, including Regulation (EU) 2016/679 of the EU and of the Council on the protection of personal data (General Data Protection Regulation, “GDPR”), you may exercise the following rights:
» The right to access personal data relating to you;
» The right to request a rectification in case you identify inaccuracies or need to update your personal data;
» The right to request blocking of your personal data or restriction of the processing of personal data in the cases defined by law and GDPR;
» The right to request deletion, i.e. erasure of your personal data in case the conditions for this are met;
» The right to object to the processing of your personal data where it is based on my or a third party’s legitimate interest;
» The right to withdraw the consent you have given for your personal data to be processed for the purposes for which you have given consent;
» The right to request portability of your personal data in a format that is commonly used;
» The right to lodge a complaint or a request for protection of your rights before the competent supervisory authority in the Republic of Bulgaria – the Commission for Personal Data Protection, address at: Sofia, 1592, 2, blvd. Tsvetan Lazarov, e-mail: kzld@cpdp.bg, website: www.cpdp.bg, telephone numbers: 02/91-53-519, 02/91-53-555.
XI. Do you have an obligation to provide me with your personal data?
In order to provide my services and enter into contractual relationship, I collect and process your personal data. I also can process personal data to comply with legal obligations.
Your refusal to provide data marked as mandatory may result in an inability to contact you (e.g. if I do not have contact details to send a response to your request), to process and respond adequately to your inquiry, respectively to conclude a contract or to continue the performance of an already concluded contract.
XII. Changes to this Policy
In the future, I may need to update this Policy in response to changing legal, technical or business processes. I encourage you to review occasionally this Website for the latest information regarding my privacy practices.
If new purposes for processing personal data or other circumstances requiring your explicit consent are envisaged, I will notify you by sending you an e-mail to the e-mail address you have provided, inviting you to kindly confirm or refuse to provide consent.
This Policy shall take effect from 01.09.2023.
Corporate, Real Estate & Regulatory Affairs lawyer with over 12 years’ experience