Privacy Policy

I. WHO ARE WE?

This website at www.icgb.eu (the “Website”) is owned and operated by “ICGB" AD, hereinafter referred to only as the "ICGB", a joint-stock company registered in the Bulgarian Commercial Register and the Register of Non-Profit Legal Entities at the Registration Agency under EIC 201383265.

The Company has its seat and management address: Sofia, p.k. 1000, Vazrazhdane District, 23 George Washington St.

The contact email address for ICBG is: office@icgb.eu

The Company carries out its activities in accordance with the legislation in force in the Republic of Bulgaria.

ICGB is a controller of Personal Information (as defined below) collected on the Website.

In this Privacy Notice “Personal Information” is information relating to you, which can be used to personally identify you (either directly or indirectly).

II. APPLICATION OF THE PRIVACY POLICY

This Privacy Notice:

• describes how we collect, use, and otherwise handle Personal Information that you provide or make available to us, or that we collect from you, when you use our Website,
• explains the circumstances in which we may transfer this to others; and
• explains about the rights that you have in relation to this Personal Information.

Our Privacy Notice must be read together with any other legal notices or terms and conditions provided or made available to you on other pages of our Website.

III. PERSONAL INFORMATION THAT WE COLLECT

The types of information that we may collect from you, depending on how you use our Websites is:

1. your name;
2. your email address;
3. your address (business and personal);
4. your landline and mobile telephone numbers (business and personal);
5. any information that you choose to provide to us when filling out a contact form on our Website;
6. your opinions when you choose to complete one of our surveys;
7. your IP address and other technical information which tells us about how you use our Website;
8. your geographic location (country/territory where you are living and/or working);
9. your job title, role, and the name of your employer;
10. the industry sector in which you work;
11. the content of your C.V. and covering letter (where you apply for a vacancy with us on our Website).

IV. HOW WE USE YOUR PERSONAL INFORMATION

1. Contact Forms - we may collect your Personal Information, which you choose to provide when you fill in forms on our Website, including the information set out in a.-e. above. We may use this Personal Information to respond to your queries and/or provide the services and/or information you requested.

2. Surveys – we may ask you if you would like to provide us with feedback on our services and/or events by completing a survey. This is optional. We use feedback from surveys to evaluate our performance and to help improve our future services and/or events.

3. Our Business Purposes - we may also use your Personal Information for our business purposes as follows:

• to manage our business;
• to communicate with you;
• to enable corporate transactions to take place;
• for record keeping, statistical analysis, internal reporting, and research purposes;
• to ensure network and information security;
• to notify you about changes to our services;
• to investigate any complaint you make;
• to provide evidence in any dispute or anticipated dispute between you and us;
• to analyse how our Website are being used;
• to customise various aspects of our Website to improve your experience;
• to host, maintain and otherwise support the operation of our Website;
• for risk management purposes;
• for business and disaster recovery (e.g., to create back-ups);
• for document retention/storage purposes;
• for database management purposes;
• to protect the rights, property, and/or safety of ICGB, its personnel and others; and
• to ensure the quality of the services we provide to our users.

If you choose not to provide the Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. Aside from this, your visit to our Website will remain unaffected.

V. LEGAL GROUNDS FOR COLLECTION AND USE OF PERSONAL INFORMATION

We process your personal information where we need to do so:

• to comply with our legal and regulatory obligations;
• for our legitimate interests;
• responding to your queries;
• providing services and/or (marketing) information to you;
• organizing events;
• carrying out surveys to obtain feedback on our services and/or events;
• recruiting personnel (except in cases where we ask for your consent); and
• our internal business purposes, as set out above.

VI. SHARING YOUR INFORMATION

We may share your Personal Information with:

• our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice;
• any other third party if we are under a duty to disclose or share your Personal Information to comply with any legal obligation;
• any other third party for the purpose of acting in accordance with the requirements of a court, tribunal, regulator, or government agency, for example, complying with a search warrant or court order.

However, we have taken steps to ensure that all such entities keep your personal information confidential and secure and use it for limited purposes that we have specified and informed you of. In relation to any other third parties, we will only disclose your information where you have given your consent or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with, legal proceedings or to exercise or defend legal rights.

We may transfer or disclose the personal data we collect to our third-party service providers such as our website operator or our third-party SIEM provider. When we transfer personal data, we do so for the purposes described in this Policy.

It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub-processors.

Your data may be delivered and processed in third countries sometimes. This can be in countries which provide adequate protection based on respective adequacy decisions of the European Commission. In any other case, we use safeguards with respect to your personal data such as data protection clauses in our contracts with data processors to ensure that processing activities in third countries are compliant with the strict requirements of Bulgarian law and the General Data Protection Regulation (GDPR).

VII. HOW LONG DO WE STORE PERSONAL INFORMATION?

It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some Personal Information for a longer period of time, considering factors including:

• legal obligation(s) under applicable law to retain data for a certain period;
• statute of limitations under applicable law(s);
• (potential) disputes and
• guidelines issued by relevant data protection authorities.

Whilst we continue to process your Personal Information, we will ensure that it is treated in accordance with this Privacy Notice. Otherwise, we securely erase your information once this is no longer needed.

VIII. SECURITY

We use up-to-date data storage and security techniques to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your information.

IX. YOUR RIGHTS

1.The right to be informed

You have the right to be provided with clear, transparent, and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Privacy Notice.

2. The right of access

You have the right to obtain a copy of your Personal Information (if we are processing it), and certain other information (like that provided in this Privacy Notice) about how it is used.

This is so you are aware and can check that we are using your information in accordance with data protection law.

We can refuse to provide information where to do so may reveal Personal Information about another person or would otherwise negatively impact another person's rights.

3. The right to rectification

You can ask us to take reasonable measures to correct your Personal Information if it is inaccurate or incomplete. E.g., if we have the wrong name or address of you.

4. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it or its use is unlawful. This is not a general right to erasure; there are exceptions, e.g., where we need to use your Personal Information in in defense of a legal claim.

5. The right to restrict processing

You have the right to ‘block’ or suppress further use of your Personal Information when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability

You have the right to obtain and reuse certain Personal Information for your own purposes across different organizations.

7. The right to object

You have the right to object to certain types of processing, on grounds relating to your situation, at any time if that processing takes place for legitimate interests pursued by us or by a third party. We will be allowed to continue to process your Personal Information if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise, or defense of legal claims.

X. CONTACT INFORMATION

If you have any questions in relation to this Privacy Policy, please contact us at: Sofia, 1000, Vazrazhdane District, 23 George Washington St. or at office@icgb.eu. If you currently receive marketing information from us which you would prefer not to receive in the future, please e-mail us at office@icgb.eu. All e-mail messages sent to and from ICBG may be monitored to ensure compliance with internal policies and to protect our business.

You can also contact the Bulgarian Commission for Personal Data Protection (cpdp.bg) at any time.

The contacts of the Commission for Personal Data Protection are as follows: address in Bulgaria, the city of Sofia, 2 Tsvetan Lazarov Bvd, 1592, tel.: + 359 02-91-53-519, e-mail: kzld@cpdp.bg.