Privacy notice

(effective as of 25.05.2018)

І. Introduction

The present Privacy notice contains the mandatory information regarding the collection, processing and storage of personal data from APIS, as well as regarding the rights of the persons in relation to their personal data protection.
This Privacy notice concerns the personal data, collected through our websites https://www.apis.bg, https://web.apis.bg and https://eurocases.eu/, through our products, seminars, webinars, trainings and other events, mobile applications and online services.

„APIS Europe" AD, hereinafter referred to „APIS", is registered as a data controller with identification № 58359 according to the requirements of the Bulgarian legislation in the field of the personal data protection, effective till 25-th of May 2018.

APIS carries out his activity in accordance with 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 (General Data Protection Regulation) and the other European and Bulgarian normative acts in the field of the personal data protection. APIS спазва следните принципи при обработката на Вашите personal data:

  • Conformity with the law, good faith and transparency;
  • Restriction of the purposes of processing;
  • Relevance with the purposes of the processing and minimum collected data;
    accuracy and topicality of the data;
  • Restriction of the storage in view of reaching the goals;
  • Entirety and privacy of the processing and guaranteeing an appropriate level of security of the personal data.

ІІ. Collection, processing and storage of personal data

Personal data is any information concerning you, through which we can identify you, for example your name, PIN, e-mail, contact number and information about your access to our websites.

You can examine the public part of the contents of our websites without entering any personal data in them. In the cases, when we collect personal data, which are necessary in order to provide you an access to information, product or service, requested by you, we shall notify you in advance for the necessity to provide us with such data, as for satisfying your request. Your approval for the collection and processing of your personal data shall be always requested explicitly in the cases, when such approval is required under the applicable legislation for the personal data protection, the relevant information for collection and processing of our personal data shall be provided prior to collection and processing of any personal data.

It is possible on some of our pages on our websites to ask you to provide your data in order to provide you with a requested service or product or in the cases, when you want to connect with us. When you register for the use of our products or provision of services- personally or through an employee of yours, we shall require from you to provide us your personal information as contact data (names, position, company or organization, at which you work, address, incl. electronic address, phone number), your citizenship and the state of permanent residence or other information, required for issuance of an invoice in connection with a payment, made by you. APIS does not collect financial information for bank cards in the cases, when payment of the price for our products and services is made online. You are not obliged to provide us with the required personal information, but if you don’t do this, APIS may not be able to implement your order or to provide you with the requested service.

If we have received your explicit approval for this, APIS may use the information, provided from you to offer you its products and services, which we consider to be of interest for you. At any time you can withdraw your approval for receiving such promotional messages by contacting us and notifying us in a chosen way by you. The contact data of APIS are specified below in the present notice as well as in „Contacts" section on our webpages. Moreover, each promotional or advertising email sent from us, contains a „subscription link", by which you can declare your refusal to obtain such messages. In case you choose to sign off from receiving promotional and advertising messages, APIS shall be obliged to delete the data for contact with you from the list of the persons, who have given approval for receiving promotional and advertising messages, not later than 3 (three) working days following the receipt of your refusal.

When you contact us in order to render you cooperation in connection with the use of our products and services, bought from us, we may ask you to provide information about your computer, operational system, browser or about the problem which you want to solve. Without this information APIS can’t help you and answer your questions.

When you use our products or services, or when you visit our websites, APIS may collect information about the contents, that you have examined and/or the searches that you have made, as well as it may store this information. In such cases we may collect information about your unique internet protocol, the browser type or the operational system, the date and time of your visit, orders for searches and the like. The aim of collecting such information is the improvement and personalization of the products and services, offered by us. Part of this information is collected through the so called „cookies". In order to make yourself familiar with the way, by which we use the cookies, please see our Cookies policy.

In its information products and services APIS provides the users with a registered access to data from public sources as subpoenas from the courts and other communications in „State Gazette", information about the traders from the Trade register with the Registry agency and etc. It is possible the information, collected from public courses, to contain your personal data. Our continuous commitment is this information to be always true and correct and to completely correspond to the data, published in the public sources.

Grounds for collection, processing and storage of your personal data

APIS collects, processes and store personal data in connection with the execution and implementation of the contracts with its clients for providing right of use and subscription service for products and services under „APIS" mark,for organization and conduction of seminars, webinars, trainings and other events.

APIS appears data controller regarding our data as users of our services. Towards the personal data which you enter, process and store, while using our online services and products, APIS acts in its capacity as data processor.

In particular, as a data controller APIS collects, processes and stores personal data on the following grounds:

  • Initiating steps upon your request for execution of a contract with you;
  • Fulfillment of the obligations of APIS under a contract with you;
  • Explicitly given consent from you;
  • Adherence to obligations, arising from a normative act;
  • For performance of a task of public interest;
  • For the purposes of the legitimate interest of APIS.

Purposes, for which are collected, processed and stored your personal data

APIS collects, processes and stores personal data, which you provide to us for the following purposes:

  • Individualization of a party under the contract and the contact persons in relation to its performance;
  • Creation of a user name and ensuring complete functionality upon provision of our services;
  • Ensuring the implementation of the contract for provision of the respective service or product, incl. sending short text messages (sms) or emails, which appear part of the functionality of the product or service, bought by the client and etc.;
  • Provision of a technical maintenance and training for work with the bought products and services;
  • Registration of participants in seminars, webinars, trainings and other events, organized by APIS;
  • Accounting purposes;
  • Statistical purposes;
  • Marketing purposes – sending information messages, including messages of advertising and promotional nature;
  • Improvement and individualization of the services and products under the „APIS" mark by offering of appropriate for you offers for new products and services, renewal of the subscription for already bought products and services, seminars and other events, which may be of interest for you.

Types of personal data, which are collected, processed and stored by APIS

APIS collects, processes and stores the following types of personal data:

  • Names, PIN, address, email, phone number – about the clients –natural persons, or about the natural persons, who manage and represent the clients, which are legal entities. These data are necessary for the execution and implementation of the contracts with the clients of the company, who use our information products and services, as well as for realization of connection with the client and for sending information to him, including upon explicitly given approval – and for sending promotional and advertising messages. Sensitive data are not collected;
  • Names, country and email- about the clients-natural persons, resp. about registered users, using 5-day free access for trying the system EuroCases, which are collected through the website https://eurocases.eu.These data are required for the execution and implementation of the contracts with the clients of the company as well as for realization of connection with the client and for sending information to him, including upon explicitly given approval – and for sending promotional and advertising messages. Sensitive data are not collected;
  • Address of the payer and contact number – for the purposes of issuance of an invoice for made payment through the website https://eurocases.eu.Financial information about bank cards is not collected, because the payment is made via PayPal;
  • Names, position, organization/company, at which works the person, email and phone number. These data are required for registration and participation in the seminars, webinars and other events, organized by APIS. Upon explicitly given approval from the person, these data can be collected, processed and stored by APIS also with a purpose of sending promotional and advertising messages. The non-provision of such approval shall not be an obstacle for registration of the person for participation in the respective event. Sensitive data are not collected;
  • Information concerning the use from you of our websites and/or products and services - IP address, operational system, browser, orders for searches and examined contents. This information is collected for improvement and personalization of the information products and services under „APIS” mark and for provision of the complete functionality of these products and services and complete functionality of our websites;
  • Information from public registers, containing personal data. This information is collected for providing the users with information products and services under the „APIS" mark.

APIS does not collect, process or store special categories of personal data (sensitive data), nor does it makes automated taking of decisions with data.

Period for storage of your personal data

APIS shall not store your personal data for a period, longer than the required one for reaching the goals, for which we process them. Upon determination of the appropriate period for storage, we take into account the quantity and nature of the personal data, the goals, because of which we process them as well as whether we can reach these goals by other means. APIS adheres to the relevant legal requirements for storage of certain data categories in order to fulfill our obligations, arising from a normative act or a contract, as well as to protect our legal rights in case of filing a claim. When the need of their storage does not exist anymore, APIS shall delete or destroy your personal data in a safe way and without unnecessary delay.

Delivery of your personal data for processing

In its individual capacity APIS collects and processes the personal data provided from you. The data shall be provided to third parties only in the cases, envisaged by law. All personal data shall be stored on the territory of Republic of Bulgaria. APIS does not make a transfer of your personal data to third countries.

ІІІ. Your rights for protection of your personal data

Upon certain circumstances you have a legal right:

  • to request information whether APIS stores your personal data as if we have such data – what are these data, on what grounds and with what purpose we process and store them;
  • to ask for an access to your personal data (the so called "order for access to data"). This shall enable you to receive a copy from your personal data, owned by APIS and to check whether we process them under the statutory way;
  • to ask for correction of your personal data, owned by APIS. This shall allow you to correct any incomplete or incorrect information, which we have about you. APIS does not correct personal data, when they are collected from a public source and completely correspond to the data, published in this source;
  • to ask your personal data to be erased (the so called „right to be forgotten"). This shall enable you to ask us to erase or remove without any unnecessary delay all or some of your personal data, if there is no reason to continue with their processing and storage. APIS does not delete the data, which it has a statutory obligation to store, including for protection in relation to filed claims against it or for proving its rights;
  • to object against the processing of your personal data, in case we refer to a legitimate interest (or the interests of a third party) and something in your particular situation makes you to object against the processing for that reason. You shall also have the right to object if we process your personal data for direct marketing purposes;
  • to request from APIS to erase or remove your personal data, if you have exercised your right to object against their processing according to the previous point;
  • to object against the automated taking of decisions, including profiling, i.e. not to be subject of any automated taking of decisions by us while using your personal data or by profiling ;
  • to ask for restriction of the processing of your personal data. This shall enable you to request from us to cease the processing of your personal information, if for example you want to ascertain its authenticity or the reason for its processing;
  • to ask for a transfer of our personal data in an electronic and structured way to you or to another person (the so called „right to data portability"). This shall enable you to take your data from us in an electronic form, fit for use and to transfer them to another person in an electronic form, fit for use;
  • to withdraw your approval. You may withdraw your approval for all or for some of your personal data, as well as for a particular or for all purposes of processing. If you have given approval for collection, processing and storage of your personal data for a particular purpose, you have the right to withdraw it at any time as regards this particular type of processing. After you notify us that you shall withdraw your approval, we shall cease the processing of the personal data for the purpose or purposes, for which you have initially given your approval, except if there is another reason to continue this processing;
  • to be notified in case of breach of your personal data security, which may lead to a high risk for your rights and freedoms. APIS shall inform you without unnecessary delay and in appropriate way in case such breach is ascertained, as well as for the measures which have been undertaken or shall be undertaken.

In order to exercise any of the above-listed rights, please send us a request or notification by a narrative description to our employee in charge for the data protection, by post or by e-mail: dpo@apis.bg, or contact him/her on the following address: Sofia 1111, Slatina region, Geo Milev quarter, № 67B „Postoyanstvo" str., entr. B.

Please take into account that we may ask you to provide particular information, which to help us to verify your identity and to respect your right for access to information or any of your other rights. The purpose of this additional security measure is to guarantee that your personal data won’t be revealed before persons, who have no right to receive them.

Exercising of the above-mentioned rights does not require payment of a fee from you. However, we may charge you with an administrative fee to a reasonable amount, if your access order is obviously groundless or in case of repetition or excessiveness of the requests. Upon such circumstances we may also reject the implementation of the order.

APIS has appointed an employee for the data protection, who observes the adherence to the rules, described in this Notice and in the normative acts, applicable to the personal data protection. If you have any inquiries regarding these rules or regarding the way, by which APIS processes your personal data, please contact our employee by e-mail: dpo@apis.bg or by phone +359 2 970 89 22.

If you consider that your rights for personal data protection have been breached, you have right to file a complaint to the Commission for personal data protection, as information about its address and other contact data you may find below in the present Notice.

ІV. Measures for ensuring protection of your personal data

APIS observes strict procedures for security upon storage of your personal data and also in order to protect them from unauthorized access, accidental loss, destruction or damage. The security of your personal data appears our priority, with which we don’t make any compromises.

APIS applies organizational, physical, information-technological and other necessary measures as to ensure the security and protection of your personal data and the monitoring of the personal data processing. The data which you provide online are protected by encrypted connection through the use of SSL certificate. SSL is a standard method in the field of personal data coding, allowing the data to be safely transferred through Internet. The personal data are stored on servers of the company or in cloud Data centers, where they are protected by all modern and fit for the purposes standard hardware and software means of protection –fire walls, anti-virus programs, data encrypting and etc.

Some of the security measures, implemented by APIS, comprise the following activities:

  • the requirements for collection, processing and storage of personal data are established in internal procedures, which observance is constantly monitored;
  • the access of the employees of APIS to personal data and the authorization for personal data processing in our data base is restricted, depending on their duties as there are also established duties for confidentiality for all employees of APIS;
  • for ensuring maximum security upon collection, processing and storage of your personal data, when necessary or appropriate, we use additional protection mechanisms as encrypting, pseudonymization and etc.
    APIS is constantly trying to improve the security measures, which we have implemented and currently use in our activity and make them in conformity with the most advanced technologies.

V. Protection of the personal privacy of children

The protection of the personal privacy of the children in today’s interactive online world is of crucial importance for APIS. Our websites are not designated for or deliberately intended to children on and under 14 years old. APIS does not collect, process or store personal information for persons under 14 years old.

VІ. Changes in the rules, described in this Privacy notice

Upon its discretion APIS may amend and supplement the present Privacy notice at any time as observing the requirements of the effective legislation in the field of the personal data protection. In case of amendment we shall specify the date of amendment and this amendment shall become effective towards you and your data after the date of the amendment or after another explicitly determined date.

Information concerning the personal data controller and the official on the personal data protection

  • Name: "APIS Europe" AD
  • UIC: 175142993
  • Seat and registered address: Sofia 1111, „Slatina" region, „Geo Milev" quarter, № 67B, „Postoyanstvo"str., entr. B
  • Correspondence address: Sofia 1111, „Slatina" region, „Geo Milev" quarter, № 67B, „Postoyanstvo"str., entr. B
  • E-mail: dpo@apis.bg
  • Contact phone: +359 2 970 89 22

Information concerning the competent supervisory body

  • Commission for protection of personal data
  • Correspondence address: Sofia 1592, No2 „Prof. Tsvetan Lazarov" Blvd.
  • Contact phone: +359 2 915 3 518
  • E-mail: kzld@government.bg, kzld@cpdp.bg
  • Website: www.cpdp.bg