Last updated: 12 September 2019
Who are we?The America for Bulgaria Foundation is a non-profit organization registered in the United States of America, Delaware State, under number 4238284, with address in the Republic of Bulgaria: Sofia 1000, 6 Malyovitsa Str. Our contact details for the purposes of this Policy are as follows: Ms. Kristina Kosheva, email address: firstname.lastname@example.org.
What information do we collect about you?
Information you give us.
This is information that you give us by filling in forms, sending inquiries and messages on our Website, as well as when further interact with us in the course of processing your project proposals, and during the execution and reporting of the funded by ABF project. 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 those pages and other statistics.
How we collect and use your information?
In general, you can browse the Website without submitting your personal information. However, there are circumstances in which you may be required to provide us with your personal data.
We collect your personal data 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 application form;
- 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; and
- In relation to any section of the Website where you deliberately and voluntarily provide personal information and data.
When using your profile in social media platforms like LinkedIn, Twitter, Facebook, Instagram, etc., we have the right to process the personal data, which you have made visible on your profile.
Briefly, 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;
- 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.
What is the basis for processing of your personal data?
- Contractual and pre-contractual obligation (performance of a contract) - firstly, your personal data is necessary for taking steps upon your request preceding the conclusion of a grant agreement, as well as for the conclusion and implementation of such 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 in the Republic of Bulgaria, and which is governed by certain principles and 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. You can contact us at any time by using the contact details listed above to request more information on how we have come to this conclusion for the different types of processing.
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 agreements.
Who do we share your personal information with?The Foundation is committed to apply 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. Except in the cases provided below, we will not disclose, nor allow any person outside the Foundation to access or use your personal information. We may share your personal data with: (i) partners and service providers of the Foundation for the purposes of implementing a contract, incl. for improvement and optimization of our Website; (II) partners of the Foundation in collaborative initiatives, co-organizers of events and other activities; (III) third parties when required by law. 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 performing the services assigned by ABF. We have the right to disclose your personal data and information to the competent authorities in the cases and under the conditions set forth in the applicable laws.
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, and about the third parties recipients of the data. You are entitled at any time to request rectification of inaccurate or incomplete data. If the request is evidently unreasonable or excessive, especially for its repetitive nature, the Foundation may refuse to take actions.
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) personal data are no longer required for the purposes for which they were collected, (ii) the consent on which data processing is based is withdrawn and there are no legal grounds for further processing, (iii) the processing is unlawful, or (iv) the erasure is required for the purposes of fulfilment of a legal obligation, applicable to the Foundation. We may disregard your request, if processing is necessary for other purposes, including public interest. The right of erasure is not absolute and your request may not be satisfied in cases where the processing of your data is necessary for ABF to comply with a legal obligation applicable to it, for the performance of a task in public interest, to establish, exercise or protect legal claims. You can contact us at the contact details listed above to get more information about deleting your personal information.
Right to object
You have the right to object to the processing of your personal data for the performance of a task in public interest, for the legitimate interests of the Foundation, including against profiling. 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.
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 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. This right does not apply to the processing necessary for the performance of a task in public interest.
Right to lodge a complaint
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.
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 complaints about the way we use your personal information, you can use our contact details listed above.
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