Privacy Policy

Last updated: 25 September 2020

Welcome on www.us4bg.org

Thank you for visiting our website. We, the America for Bulgaria Foundation (“the Foundation”, ”ABF”, “we”, “our” or “us”), take to heart your privacy. We continue and strengthen our commitment to provide adequate protection of any personal information you give us. The present updated version of our Privacy Policy is intended to comply with the requirements of the General Data Protection Regulation (GDPR), effective from 25.05.2018, and the Personal Data Protection Act of the Republic of Bulgaria.

The Website uses cookies under the terms and conditions described below in the Cookies Policy.

Who are we?

The America for Bulgaria Foundation is a non-profit organization registered in the United States of America, Delaware State, under number 7755058. It carries out its activity on the territory of the Republic of Bulgaria through its branch with address: Sofia 1000, 6 Malyovitsa Str. Our contact details for the purposes of this Policy are as follows: Ms. Kristina Kosheva, email address: dataprotection@us4bg.org.

Why do we need you to read our Privacy Policy?

Please, take time to read the following Privacy Policy carefully. It highlights a number of questions, including what personal information we collect through our website and the purposes for which we process it.

By using www.us4bg.org or our landing page (the "Website"), irrespective of whether you are just visiting it to make yourself familiar with us and our activity, use it to apply for funding, submit application/ project proposal for participation in ABF’s announced requests for proposals for funding of projects, subscribe to our monthly newsletter, or send us a message by completing the contact form, you share information which may contain personal data.

In the course of performing some of the above actions, you may be required to provide certain personal information, such as name, address, mobile number, e-mail, etc. You are entitled to choose whether or not to provide us with your personal data. In the event you decide not to share them with us, we will not be able to process your application, contact you and/or assist you with information.

We reserve the right to amend and update this Policy from time to time. In such cases, the current version will always be available on our Website and, when necessary, you will be notified about this in due form (e.g. by email). The date of the last update will be indicated at the top of the Privacy Policy.

Please note that the practices described in this Privacy Policy apply only to information you provide us when using our Website. These terms do not apply to information you have provided on pages maintained by other organizations.

What information do we collect about you?

Information you give us.

This is information that you give us by filling in forms, sending inquiries for funding, submitting applications or project proposals for participation in requests for proposal, sending messages on our Website, subscribing to our monthly newsletter, as well as when further interacting with us in the course of processing your project proposals, and during the execution and reporting of the projects funded by ABF. This information may include your identification data, contact details (e-mail, address and phone number), financial information, etc., which may be required for further processing of your data in relation to a grant agreement ("grant/micro grant agreement”).

Information we collect about you.

Like many site operators, we collect information that your browser sends whenever you visit our Website ("Log Data"). The Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, pages of our Website that you visit, time and date of your visit, time spent on the Website or its pages and other statistics.

We use Google Analytics service provided by Google and, if you are a user with residence in the European Union, EEA or Switzerland, the controller of your personal data is Google Ireland Limited. This service collects and processes information about your actual location and other technical information about your visit on our Website. For this purpose we use "cookies" as described below in this Policy ("Cookies Policy"). The information collected by Google Analytics includes the Internet protocol (IP) address used to connect your computer or another device to the internet, click stream to, through and from our site (including date and time), page interaction information (such as scrolling, clicks, and mouse-overs). Google Analytics use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points and power supply. You can withdraw your consent at any time by downloading and installing the suggested browser, or by managing your consent in the box of opt-out cookies. Both options prevent web analytics only if you use the browser on which you have installed this plug-in or if you do not delete the refusal cookie. For more information check Google Terms of Use and Privacy Policy. Please refer constantly to Google website for changes or updates to these terms and to the information collected by Google Analytics.

Our Website uses Facebook Pixel – a tool of Facebook Inc. or if you are located in the EU, or you are a user with residence in the European Union, EEA or Switzerland, the controller of your personal data is Facebook Ireland Ltd. (Facebook) for analytical purposes as well as optimize and economically exploit the Website. Using Facebook Pixel, Facebook has the ability to identify visitors to our Website as a target audience for Facebook and other company-related platforms (Instagram, Messenger, Whatsapp, etc.). Accordingly, we can use Facebook Pixel to display the ads we post on Facebook to Facebook users who are interested in this Website and/or our Facebook page and thus make sure that our Facebook ads match the potential user interest. We may use Facebook Pixel to track and analyze the efficacy of Facebook ads for statistical and marketing research purposes. When visiting our Website, the Facebook pixel establishes a link between your browser and the Facebook server and sets a cookie. This information is stored by Facebook and processed in such a way that Facebook can link it with your Facebook account and your visit to our Website will be recorded in your Facebook account. We do not have access to and do not receive the data collected about you from Facebook. However, Facebook stores and processes the information so that it is possible to link it to users’ profile. For more information, please refer to Facebook’s Privacy Policy where you can find out more about how Facebook Pixel works and how Facebook ads are displayed (https://www.facebook.com/about/privacy). You can object to the use of cookies on your computer in general by configuring your browser in such a way that no more cookies will be stored on your computer and any existing cookies will be deleted.

Information we create about you.

If your inquiry for funding, submitted application or project proposal has been approved and you have received the requested funding from the Foundation, you may be invited to participate in photo and/or video sessions organized by the Foundation for illustrative purposes, in which you may present your view about your participation in our programs and projects. Such materials containing your personal data might be published in our monthly electronic newsletter, as well as on the Foundation's Website and/or social networks.

How we collect and use your information?

When you visit the Website there are circumstances in which you may be required to provide us with some of your personal data. This is applicable in the following cases:

  • When applying for funding in order to be able to process your inquiry, to contact you, including to send you our set of application documents in case your inquiry is approved;
  • When you fill in and submit an online application/project proposal for participation in a request for proposal (RfP) procedure for funding projects to review your project proposal; to contact you at the contact details provided by you and to answer your questions related to the RfP; to invite you to participate in an online meeting or webinar in order to provide you with additional explanations and to answer questions related to a request for proposal; to invite you to an individual meeting or interview as part of the process of evaluation and selection of projects participating in the request for proposal;
  • When you subscribe to receive our e-newsletter in order to be able to send it to you until you unsubscribe;
  • When you participate in a survey, study, discussion panel for the purposes of their conduct and results analysis;
  • When you register for and participate in our programs, activities, initiatives and events for the purpose of conducting them;
  • When you have requested to receive information or assistance by filling in our contact form to send you a personalized reply;
  • When you reply to ABF’s questions in the process of processing your application for funding, for the purposes of its overall assessment, possible approval and allocation of the funds;
  • When you participate in communities, virtual chat rooms, and use other interactive services in order to administer our programs and projects and the concomitant activities;
  • In connection with the verification of the information you provide to verify your identity and prevent violation of the Terms and Conditions of use;
  • In the course of our communication regarding projects, initiatives, events and other activities published on the Website;
  • When making comments or giving us additional information in a section of the Website that allows it;
  • In relation to any section of the Website where you deliberately and voluntarily provide personal information and data.

When using your profile in online platforms like LinkedIn, Twitter, Facebook, Instagram, etc., we may process the personal data, which you have made visible on your profile.

We process your personal information and data for the following purposes:

  • Responding to your inquiries;
  • Processing your requests/applications for funding and communicating with you;
  • Reviewing and evaluating your applications/ project proposals for participation in request for proposal procedures announced by ABF and communicating with you;
  • Sending our application form, as well as for subsequent processing of the data for the purpose of entering into, implementing and reporting of a grant/micro-grant agreement;
  • Sending information about the various features on our Website or news about the Foundation;
  • Notifying you of any updates of our policies;
  • Personalizing the communication with you;
  • Sending newsletters, letters, invitations to events as well as information about programs, initiatives, activities and projects by e-mail or otherwise; For registration for an event or participation in a program;
  • Optimizing and improving our initiatives and activities;
  • Research and development of our activity;
  • Editorial purposes in respect of publications related to the Foundation's activities;
  • Detecting, investigating and preventing actions that may be in violation of our policies or are illegal;
  • Developing new programs in which you may participate and receive our support.

What is the basis for processing of your personal data?

  • Performance of a contract and taking steps at your request prior to entering into a contract with us - your personal data is necessary for reviewing your inquiry, application or project proposal for funding, as well as for the conclusion and implementation of grant/micro-grant agreement;
  • Compliance with a legal obligation - the processing of your data is necessary for us to comply with the obligations imposed by the applicable laws, for example, for financial and accounting purposes.
  • Performance of a task carried out in the public interest - in many cases our projects and the related data processing activities are based on the need to perform a task in the public interest.
  • Your consent - we rely on your consent to send you our monthly newsletter and to inform you about and involve you in various initiatives of the Foundation, including trainings, conferences, seminars and other events related to our projects and programs; to share your data with our partners and to notify you of any changes in our organization and activity.
  • Legitimate interests - your personal data are also needed for the purposes of our legitimate interests as a funding organization providing grants, supporting the private sector and related democratic institutions in the Republic of Bulgaria, and which is governed by certain principles and the highest standards of ethical conduct, transparency, and core values. Our activity is subject to internal and external audit. In addition, we need your personal data in order to prevent possible misuse of the allocated funds. In order to follow our overall mission and its supporting strategies, we need to promote and evaluate the results of each and every project. Given the limitations on the processing of personal data, safeguards and protection measures applied by us, the Foundation, after an analysis, has come to the conclusion that when processing your data is based on our or third party’s legitimate interests, your interests, fundamental rights and freedoms are adequately and sufficiently protected.

How long do we retain your information and what are the criteria?

We store your data only for the term necessary for the specific purpose for which data are collected, or for the periods prescribed by applicable laws. In case your application for funding is approved, your personal data will be retained for a period of time according to the Foundation's internal policies regarding the conclusion, implementation and reporting of a grant/micro-grant agreement. For more information about the retention terms of your personal data you may contact us at any time at the above contact details.

Who do we share your personal information with?

The Foundation is committed to applying the highest standards of ethical and legal practices in all its activities, including the protection of the personal data of all users of the Website. The Foundation may share and/or transfer your data or part of it to 1) its partners in collaborative initiatives, co-organizers of events and other activities; 2) contractors (service providers established within and outside the EU which are committed by virtue of a contract with us to support ABF in its activities and in complying with the principles described in this Privacy Policy, incl. for improvement, optimization and security enhancement of our Website; 3) competent authorities in the cases and under the conditions set forth in the applicable laws. The personal data you provide to us through sending an inquiry for funding, application form or project proposal may be provided, if necessary, to third parties participating as independent experts and assisting the Foundation in the process of evaluation your application and/or in managing the ABF funding under a program. These data recipients are legally or contractually obliged to protect the confidentiality and security of your personal information and data. They are not authorized to use, disclose or modify this information in any way except for the purposes of implementing ABF initiatives and performing the activities assigned by ABF. Some recipients of your data may be located in third countries. The non-EU countries concerned may not provide the same level of protection of personal data as your country. In such cases, the Foundation will ensure that personal data are adequately protected by data recipients in these countries through the mechanisms for lawful data transfer to third countries under the GDPR. For more information about the data transfers and the applied transfer mechanisms, you may contact us at any time at the above listed contact details.

What are your rights?

Right of access and right of rectification

You have the right to receive information about what personal data of yours are being processed by the Foundation, about the data source and the purposes of their use, about the third parties recipients or categories third parties recipients of the data, as well as other aspects of the processing of your data. You are entitled at any time to request rectification of inaccurate or incomplete data.

Right of data erasure (right to “be forgotten”)

You are entitled to request the erasure of your personal data in specific circumstances, e.g. (i) if you think that your personal data are no longer required for the purposes for which they were collected, (ii) if you withdraw the consent on which your data processing is based and you believe that the Foundation has no legal grounds for further processing, (iii) if you consider the processing is unlawful, or (iv) the erasure of your data is required for the purposes of fulfilment of a legal obligation, applicable to the Foundation.

Right to object

You have the right to object to the processing of your personal data for specific purposes. However, even if you object to a particular processing, we may proceed with it, if is permitted or required by the applicable laws, for example, in order to be able to meet legal requirements or fulfil our contractual obligations to you.

Right to restriction of processing

You may request the processing of personal data to be restricted if (i) you believe your personal data is inaccurate in order for us to verify its accuracy; or (ii) you consider the processing to be unlawful, but you do not want the data to be erased, or (iii) you have objected to data processing for the purposes of our legitimate interests, or (iv) you consider we no longer need your personal data, but you require them to establish, exercise or protect legal claims. The Foundation will restrict the processing of your personal data without deleting it when the accuracy of your personal data is argued by you and this cannot be verified, or when the retention of your personal data is necessary for documentary purposes.

Right of consent withdrawal

If at any time you have given your consent to the processing of your personal data, you may withdraw this consent for future processing to which this consent refers. In case you want to withdraw your consent for receiving our newsletter, please select the "unsubscribe" option in the email. Please note that the withdrawal of consent does not affect the lawfulness of processing of your personal data on another valid legal basis and lawfulness of the processing on the basis of the consent given before withdrawal.

Right of data portability

In certain cases, you are entitled to receive your personal data you have provided to us on the basis of a contract or with your explicit consent in a structured, commonly used and machine-readable format, and you might request that we transmit this data directly to another data controller when technically possible.

Right to lodge a complaint to supervisory authority

If you consider that your personal data processing is in violation of the legal requirements, you have the right to lodge a complaint with the competent supervisory authority. Use the following link to find the competent authority in the EU Member State of your habitual residence, place of work or place of the alleged infringement: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. It is recommended that you address your claims to the Foundation first in order to get a quicker and more effective solution to the problem. Please, note that your right of access to data may be restricted in whole or in part, considering your fundamental rights and legitimate interests, in the cases provided by law. The Foundation may refuse to respond to your request to exercise your rights when it is unfounded, as well as when this is necessary for reasons of important public interest or to protect the rights and freedoms of other individuals. In any case, you will be promptly and duly informed of the decision and the reasons for it regarding any request to exercise your rights.

What to do if you want to exercise your rights or contact us for more information?

In order to exercise your rights, you may submit a request to the above listed email address.

If you would like to receive additional information or have any questions about the way we use your personal information, you can use our contact details listed above.

Cookies Policy

In order to provide an optimal user experience during your stay on our Website, the Foundation uses cookies (including in the services provided by Google Analytics and Facebook Pixel as described above) to obtain certain user information on how and when certain sections of our Website are viewed and the number of people that have visited them. A cookie is a small text file that a website saves on your computer or mobile device when you visit the Website and it enables the Website to remember your actions and preferences over a period of time, so you don't have to keep re-entering them whenever you come back to the Website or browse from one page to another.

Our Website uses the following types of cookies:

  1. Essential cookies are necessary for the Website to work and enable you to move around it and to use its services and features such as navigating between pages and accessing protected parts of the Website. This Website cannot perform properly and smoothly for you without these necessary cookies, which are automatically activated (i.e. before you select “I agree” button).
  2. Functional cookies let you optimize Website operation by giving you access to specific functions. Functional cookies collect information about your choices and preferences such as your language preferences, and more. By refusing these cookies, you may not be able to access the full information on the Website.
  3. Marketing cookies are used to track a user across websites to target advertising to a user. Their goal is to display ads that are relevant to and attractive to the individual user, making them more valuable to publishers of third-party ads and advertisers.
  4. Third-party cookies: Facebook, Twitter, Youtube, Vimeo, Flickr, Storify and other may place cookies on our Website to share content on social networks or for access statistics and analytical purposes. The presence, number and status of cookies may depend on how you use these platforms before or during your visit to the Website. For more information, please refer to the relevant cookie policy of respective social network.

By choosing the “I agree” button in our cookies banner or continuing to use our Website without changing your browser settings, you are agreeing to our use of cookies. You agree to the use of all cookies, including, but not limited to, Google Analytics and Facebook Pixel as described above.

You can set your browser to refuse, remove or block cookies already stored on your computer anytime, or you can also set the browser indicate to you when a cookie is generated without affecting the use of most features on the Website. For more information about cookies, please visit: www.allaboutcookies.org.