კონფიდენციალურობის პოლიტიკა

This privacy policy governs the use of your personal data by „Fostering Legal Migration from Moldova and Georgia to Bulgaria“– this project has received funding from the Asylum, Migration and Integration Fund 2021-2027, under Grant Agreement No 812108-44-11.06.2024; communicate with us via e-mail.

The   European Institute Foundation strongly values our own privacy – and therefore are committed to protect your personal data (i.e. information that identifies you) as though it is our own.

One of your rights under applicable law, particularly Regulation [EU] 2016/679, or as it is otherwise known, the GDPR – is that you must be informed when your personal data – also known as personal information – is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.

This privacy policy describes our practices relating to the personal data of visitors of   www.cometobg.eu and make use of our online facilities. For all our services, the data controller — the company that’s responsible for your privacy — is European Institute Foundation, Bulgaria.

If you have any questions about how we protect your privacy, get in touch here:  office@europe.bg

We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.

Most of the personal information which we may collect about you through this website is given to us only if you choose to give it to us.

If you send us emails, then the personal data we process will depend on what you send us in the email.

 The information is given to us because you accessed this website (e.g. logs, recorded through cookies). This is explained in our Cookies Policy.

We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected.

The tables below set this out in detail, showing what we do, and why we do it.

Information you give us when you browse our site or use our app, including your IP address and device type and, if you choose to share it with us, your location data, as well as how you use our website and app.

How we use information about your phone or laptop, and how you use our website and app	Why?
Improve our website and set default options for you (such as language)	To give you the best browsing experience
Protect our website	To prevent and detect fraud against either you or us — and to meet our legal obligations about looking after your data

You don’t have to give us any of this personal information but if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.

We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including, research, data analysis and improving our site.

For some of the uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent.

This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you, provide customer-care and support services to you.

It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:

• to ensure that you know about any changes to the website or the terms of this Privacy Policy.
• to improve and ensure the security of the website (for example, for statistical, testing and analytical purposes, troubleshooting).

We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.

We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

As a guide:

• • we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute;
  • and, we may keep different types of personal data for different lengths of time if required by law;

You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us at office@europe.bg.

If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us.

We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.

We do not, and will not, sell any of your personal data to any third party. It is not our business to do so – and we want to earn your trust and confidence. However, we share your data the rest of the members of the European Institute Foundation.

• In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
• When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended – again, we don’t want you to have any surprises.
• We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous.
• If we ever have to share data with other entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.

You enjoy several rights relating to your personal information:

1. The right to be informed about how your personal information is being used;
   We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.
2. The right to access the personal information we hold about you;
   You can access the personal data we hold on you by contacting us at office@europe.bg.
   To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person.
   We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format.
   If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority.
3. The right to request the correction of inaccurate personal information we hold about you;
   We appreciate feedback from you to ensure our records are accurate and up-to-date.
   If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us at office@europe.bg.
4. The right to request that we delete your data, or stop processing it or collecting it;
   You can ask us to delete your personal data; however, this is not an absolute right.
   In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation; and (ii) in relation to the exercise or defence of any legal claims.
   When you ask us to delete your personal data, we assume that you do not want to hear from us again. Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.
5. The right to object to certain processing based on legitimate interest;
   You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.
6. The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
7. The right to withdraw consent for other consent-based processing at any time;
8. The right to request that we transfer or port elements of your data either to you or another service provider;
   You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help.
   If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.
   Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide.
   When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
9. The right to complain to your data protection regulator
   If you want to exercise your rights, have a complaint, or just have questions, please contact us at office@europe.bg.
   Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

Security of your personal data is very important to us.

Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us.

Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:

1. Use of secure hosting;
2. Use of SSL/TLS communication protocol
3. Use of back-up systems.

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur. 

Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time.

We therefore encourage you to check our privacy policy on a frequent basis.

This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.

Therefore, we encourage you to read the privacy statements on the other websites you visit.

We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.

If you have any questions about the Website Privacy Policy, or if you wish to make a complaint about how we have handled your personal information while using the website, please contact us at office@europe.bg.

We have appointed a Data Protection Officer (Apostol Apostolov) in charge of Website Privacy Issues who may be contacted at office@europe.bg.