Privacy and Cookies Policy

I. Declaration on the personal data protection policy

V.A.V. Consultants Ltd. (V.A.V.) has an obligation to inform you what to expect when processing your personal data.

With this document, the V.A.V. ensures compliance with EU and Member State legislation with regard to the processing of personal data and the protection of the "rights and freedoms" of persons whose personal data V.A.V. collects and processes under the General Data Protection Regulation (Regulation (EU) 2016/679).

For the processing of personal data to be carried out in accordance with legal requirements, personal data are collected and used lawfully and the V.A.V. has taken the necessary measures not to be subject to unlawful disclosure, subject to the following principles:

1. processed lawfully, in good faith and in a transparent manner with respect to the data subject ('lawfulness, good faith and transparency');
2. collected for specific, legitimate purposes and not further processed in a way that is not compatible with those purposes ('purpose limitation');
3. the data collected are limited to what is necessary in relation to the purposes for which they are processed ('data minimization');
4. V.A.V. has taken measures to promptly delete or correct inaccurate personal data, taking into account the purposes for which they are processed ('accuracy');
5. the data shall be collected and stored for a period not exceeding what is necessary for the purposes of the processing of personal data; ('storage restriction');
6. the data collected are processed in such a way as to ensure an appropriate level of security of personal data, protection against unauthorized or unlawful processing, accidental loss, destruction or damage ('integrity and confidentiality');
7. The V.A.V. is able to demonstrate that it complies with the basic principles relating to the processing of personal data ('accountability').

II. Scope of the Policy and performed by V.A.V. personal data protection activity

This Policy constitutes summarized information regarding the storage, usage, and security of User's personal data that has become known through the latter's visit to V.A.V. `s Website and the use of its functionalities, as well as the use of the respective services of V.A.V.

V.A.V. respects the rights of all Users of privacy and protection of their personal data and undertakes not to use provided data without their consent. As a controller of personal data V. A. V. collects, processes, stores and transmits User's personal data in the manner described in this Policy. Collected by V.A.V. personal data may include names, birthdates, addresses, emails, telephones, passport data, ID card details, profiles on other websites, etc., and the list given is non-exhaustive and has exemplary nature.

Users should bear in mind that V.A.V. under any circumstances does not require, collect, process, store or transmit information containing personal data about them which (i) reveals racial or ethnic origin; (ii) reveals political, religious or philosophical beliefs, membership in political parties or organizations, associations with religious, philosophical, political or trade union purposes; or (iii) refer to health, sexual life or to human genome.
Users should not disclose and publish such information when using the Website or services of V.A.V., and a possible disclosure by Users of such information could not bind the responsibility of V.A.V. in any way.

III. Collection and processing of personal data by V. A. V., purposes of use

Users' personal data are collected and processed by V.A.V. using the functionalities of the Website.
Duly collected and processed by V.A.V. private user data can be used for either/any of the following purposes: identification of Users

Duly collected and processed by V.A.V. User's personal data may be used for any of the following purposes: User identification; provision of information for the offered by V.A.V. services; information campaigns; improving certain functionalities of the Website; with statistical objective and analysis; (direct) marketing and behavioral advertising; sending unsolicited commercial messages, etc.

The above purposes of use of personal data are listed non-exhaustively and V.A.V. has the right to change them unilaterally and at any time, respecting the legal rules and requirements.

IV. Cookies

Like many other websites, this Website uses cookies. Cookies are small text files that are stored on the device /browser of Website`s Users. They allow us to determine Users preferences by recovering their information. Cookies do not give access to information stored on the User's device. Cookies do not store personal information of Users, but can be associated with files that contain such information voluntarily provided by Users. By being present on the Website, the User agrees that the Website may also place cookies on its device and / or browser in order to provide full and quality access to the services provided by V.A.V.

Users can refuse the use of Cookies by changing their browser settings, but in this case V.A.V. Will not be able to provide in full all the functionalities of the Website and the services. With the presence on the Website, the User agrees V.A.V. to use the information obtained by Cookies, and with the ability to provide it to third parties.

The User agrees that the Website allows the use of Cookies from third parties, excluding V. A. V. In order to obtain more information and questions about third party cookies used, users should direct inquiries to relevant third parties. V. A. V. is not responsible for the content or use of Cookies, placed on Users` device/browser by third parties.

V. Disclosure of personal data

In some cases, observing the statutory rules and requirements, and to protect the interests of V. A. V. or third parties, V. A. V. has the right to disclose information about Users when such disclosure is necessary in view of:

• ensuring the protection, exercise or preservation of the legal rights, privacy, safety or property of V.A.V., its employees, or contractors, or other Users, and members of the society;
• providing protection against fraud or for risk management purposes;
  compliance by V.A.V. with legal requirements;
• execution of requests by competent authorities made in accordance with applicable legal requirements;
• in other cases prescribed by the law, current Policy and V.A.V.s` Website Terms and Conditions, which refer to it.

VI. User Rights

Users have the right to receive from V. A. V. a complete, comprehensive and up-to-date information on the collection, processing, storage and transmission of their personal data and data about persons, which they constitute, in connection with the activities of V. A. V.

Users whose personal data are collected, processed, stored and transmitted have the right at any time to object before V.A.V. against the above actions with their personal data (and to request their deletion, correction or blocking), as well as to request V.A.V. to notify third parties to whom the relevant personal data have been disclosed about the correction or deletion of specific personal data, except where such notification is impossible or inadequate.

Users should be advised and agree that, upon revocation of their consent or refusal to provide information representing personal data, V.A.V. has the right to restrict access to its Website, respectively to refuse to the particular User access to any or all offered by V.A.V. services.

User to whom processed personal data refer has the right to object before V.A.V. against the processing of his/her personal data for direct marketing purposes, to be informed before his/her personal data are disclosed for the first time to third parties, or used on his/her behalf for the purpose of direct marketing, by objecting against such disclosure and use by sending an email to vav@vavconsultants.com.

By accepting this Policy, the User agrees that V.A.V. has performed the initial notification of the User and has the right to disclose his or her personal data to third parties for direct marketing purposes.

VII. Security and protection of stored User's personal data

V.A.V., as a personal data administrator, places the secure storage and personal data protection as one of its main priorities.

Personal data and information provided by Users are protected by law and V.A.V. shall exercise due diligence, using appropriate technical, administrative and operational standards to prevent unauthorized access to or misuse with stored personal data. V.A.V. stores the personal data collected in the territory of the Republic of Bulgaria.

VIII. General provisions

All specific concepts (headings) used in this Policy are identical to the definitions given in Website Terms and Conditions for http://www.vavconsultants.com/.

This Policy is an integral part of Website Terms and Conditions for http://www.vavconsultants.com/, which refer to it.

Last Updated: January 2022