This Privacy Policy has been adopted and uploaded by Leader- 96 Ltd. (“We”, “Us”, “Our”, “Leader-96” or “Personal Data Controller”) in observation of the requirements of the Bulgarian law and 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, and repealing Directive 95/46/EC (shortly “GDPR”).

We hereby inform you that certain type of personal data is collected when using our website www.leader96.com, or using some of its features, or when using any mobile application created for it (collectively the “website”). Please, carefully read the text below.

As we highly value protection of the privacy and personal data of the visitors of our website we have implemented all necessary technical measures to secure the safe experience on our website and usage of its functions, as well as to protect the rights of the visitors.

For the avoidance of any doubt, where mentioned in the text hereinbelow, the terms “user”, “visitor” and “data subject” shall mean one and the same and shall refer to the physical persons, whose personal data may be collected and processed during the usage of our website.

1. Personal Data Controller

The personal data controller responsible for the processing and storage of the personal data is:

LEADER 96 Ltd,, a sole- owned limited liability company, incorporated and existing as per the Bulgarian law, entered in the Bulgarian Commercial Register under UIC 115018980, having its seat and registered address at 3 Vazrazhdane Str., village of Rogosh, Maritsa Municipality, Plovdiv District, Republic of Bulgaria

Address for correspondence: 3 Vazrazhdane Str., village of Rogosh, Maritsa Municipality, Plovdiv District, Republic of Bulgaria

Contact Person:  Antonia Todorova

Tel.: +359 32 511 570

E- mail:  office@leader96.com

2. Types of Data Collected and Processed

The types of personal data collected and processed by us is ruled by the principle of data minimization. We limit data collection and processing to only what is required for the fulfillment of the specific purposes of our website features.

Depending on the functionality of the site and the services you use, the following personal data may be collected and processed:

To access and view our site: Your IP address, redirect URL, domain, geolocation of your device (if and when allowed by you through the settings of your device).

To participate in our recruitment process and send your CV: your IP address, redirect URL, domain three names, phone number, email, date of birth and other information specified in the CV sent

To joint our newsletter: your IP address, redirect URL, domain, your email.

3. Lawfulness of the Processing. Legal Grounds.

The legal grounds on which we collect and process personal data is the consent of each user/visitor of our website given by clicking the button “I have read and agree with the Privacy Policy”.

We provide each individual user/visitor with the technical opportunity to firstly read this Privacy Policy before clicking the button “I have read and agree with the Privacy Policy”. Thus, each individual user/visitor can be duly informed on all legislatively prescribed data protection issues.

Each user of the website has the right to withdraw its consent at any time by sending notification to Leader-96 via e- mail or by courier/registered post.

4.Purposes of the Processing.

The purpose for processing of the data collected are strictly related to the use of the features of our website.

When personal data is collected with respect to applying for a vacant job position via our website the purposes for its processing and storage are defined by the recruitment process, such as shortlisting, interviewing candidates, etc.

We use Cookies on our website. Cookies represent small text files that websites save locally to your computer, thus allowing those websites to store and use certain information about you during your visit in order to improve your browsing experience on our website, to analyze our website traffic, to understand where our visitors are coming from and what pages they prefer, etc. For more information on the type of Cookies used by us, the personal data collected through their usage and how to turn Cookies off please, read the document Cookies on www.leader96.com/cookies/ which represents inseparable part to this Privacy Policy.

5. Period of the Processing

We process and store the collected personal data only for the period necessary for the fulfillment of the respective purposes for which it has been collected by us.

With respect to the personal data collected during a recruitment process carried by us the overall period of the storage of the personal data collected does not in any case surpass 6 (six) months, unless the respective job applicant has provided its explicit consent for a longer period.

Please, note that the Google Analytics cookies used by us are “persistent cookies” and they expire after 26 months, reckoned from their initial allocation on your computer/device.

6. Who Do We Share Personal Data With? Transfer of Data to a Thirdy Coutnry.

Your personal data is usually processed within our company. Depending on the types of data and the purposes for which it is collected, access to your personal data is allowed only to certain departments/organizational units. These units include, in particular, our IT department, our HR department, and Marketing department

To the extent necessary and only if required by the law your personal data is shared with third- party service providers such as Google. In this case Google, in its capacity of personal data processor and in observation of the law undertakes all necessary measures to preserve your personal data.

Personal data are usually processed within the European Union or the European Economic Area;

Data may be transferred to recipients in the so-called “third countries” out of European Union only in connection with the use of the services of service providers, such as the USA for example in case of using Google, Linkedin, Youtube, and Instagram services. “Third countries” mean countries outside the European Union or the European Economic Area, where a level of data protection comparable to that in the European Union is not guaranteed.

We hereby guarantee that the personal data transfer is made in accordance with GDPR requirements and receives adequate level of protection through the implementation by Google, Youtube, Instagram, and Linkedin of the European Commission’s Standard Contractual Clauses.

7. Rights of The User/Visitor

When personal data of an user/visitor of our website is collected and processed, the user/visitor becomes a data subject in the sense of the GDPR and has the following rights:

7.1. Right to Withdraw His/Her Consent

The data subject has the right to withdraw his/her consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal can be performed either by sending a letter via courier/registered post to Leader 96 Ltd, 3 Vazrazhdane Str, Plovdiv municipality, Bulgaria, or by sending an e- mail to office@leader96.com.

7.2. Right of access by the data subject

7.2.1. The data subject shall have the right to obtain from the personal data controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
• the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Please, note that Leader- 96 does not use automated decision- making, or profiling for its website.

7.2.2.   Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

7.2.3.   The personal data controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

7.2.4. The right to obtain a copy referred to in item 7.2.3 above shall not adversely affect the rights and freedoms of others.

7.3. Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

7.4. Right to erasure (‘right to be forgotten’)

7.4.1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

7.4.1.1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

7.4.1.2. the data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing;

7.4.1.3. the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);

7.4.1.4. the personal data have been unlawfully processed

7.4.1.5. the personal data has to be erased for compliance with a legal obligation in the European Union or one set forth by the Bulgarian law to which the controller is subject

7.4.1.6. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

7.4.2. The right to erasure cannot be exercised in the following cases:

7.4.2.1 for exercising rhe right of freedom of expression and information

5.4.2.2. for compliance with a legal obligation which requires processing by the European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

7.4.2.3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) of GDPR;

7.4.2.4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of GDPR in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

7.4.2.5. for the establishment, exercise or defence of legal claims.

7.5. Right to restriction of processing

7.5.1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

7.5.1.1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

7.5.1.2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

7.5.1.3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

7.5.1.4. the data subject has objected to processing pursuant to Article 21(1) of GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

7.5.2. Where processing has been restricted by the data subject, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

7.5.3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

7.6. Notification Obligations of The Personal Data Controller

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with the legislation in force to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

7.7. Right to Data Portability

7.7.1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

7.7.1.1. the legal basis of the processing is based on consent and

7.7.1.2. the processing is carried out by automated means.

7.7.2.   In exercising his or her right to data portability the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

7.7.3. The exercise of the right to data portability shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7.8. Right to object

7.8.1.   The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

7.8.2.   Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

7.8.3.   Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

7.8.4.   At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

7.8.5.   In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

7.8.6.   Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.9. Right to lodge a complaint with a supervisory authority

Each data subject is entitled to file a complaint regarding the processing of his/her personal data with the Bulgarian Commission for Personal Data Protection, which is the competent supervisory authority for the Republic of Bulgaria. The contact details of the Bulgarian Supervisory Authority are specified in item 8 below. The complaint or alert can be done in one of the following ways:

1. In person – at the Commission for Personal Data Protection Registry at: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
2. By registered post or via courierto: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Commission for Personal Data Protection.
3. By fax: +3592/91-53-525.
4. By e-mail – kzld@cpdp.bg. IMPORTANT! When loging a complaint in this way, the complaint must be formed as an electronic document signed with a qualified electronic signature (QES). The commission takes no action for complaints that are scanned or photographed and submitted to its e-mail, but not signed with QES.
5. By the Secure Electronic Service System, maintained by the Bulgarian State e-Government Agency

You can also file a complaint regarding the processing of your personal data using our help by sending e-mail to office@leader96.com.

8. Contact Details of The Commission for Personal Data Protection

Commission for personal data protection (CPDP)

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

GPS coordinates: N 42.668839    E 23.377495

Е-mail: kzld@cpdp.bg

Web-site: www.cpdp.bg

Tel. 02/91-53-519