PRIVACY POLICY in www.prolotherapyschool.com
This document discloses the Privacy Policy and the protection of personal data collected by users of the Site at (URL) www.prolotherapyschool.com.
The site www.prolotherapyschool.com is owned by “EUROPEAN SCHOOL OF PROLOTHERAPY ESP” Ltd.
This Privacy Policy is intended to inform you about how the owner of www.prolotherapyschool.com treats your personal data as an administrator, as well as how you can control your preferences and settings in connection with this treatment.
Please read this Privacy Policy carefully before accessing the Site and its services. If you do not agree to any of the terms, you should not visit the Site and do not use in any way the services it offers.
This Privacy Policy is an integral part of the General Terms and Conditions of the Site www.prolotherapyschool.com.
All definitions given in the General Terms and Conditions are also applicable in this Privacy Policy.
WHAT DOES THIS PRIVACY POLICY REGULATE AND WHAT LEGAL BASIS DOES IT APPLY TO?
From May 25, 2018, the General Data Protection Regulation (GDPR) is applied in Bulgaria. It has been adopted by the European Union and aims to harmonize the policies of the EU Member States regarding the collection and use of personal data. The new regulation comes with a number of requirements that www.prolotherapyschool.com applies. Among them are:
To inform you what data we use.
To inform you why we use them.
To ask for your consent to use them.
To give you the opportunity to change your consent for different processing purposes.
The ability to delete them, as well as to be “forgotten”.
To indicate all third parties / other companies with whom we exchange your data.
This Privacy Policy applies to your personal data when you visit www.prolotherapyschool.com or use our services, but does not apply when you use other sites or services that we do not own or control.
PERSONAL DATA ADMINISTRATOR
In order to meet the requirements of the applicable legislation for personal data protection, the company responsible for the protection of your personal data in their capacity as data Administrator is:
1. Name: “EUROPEAN SCHOOL OF PROLOTHERAPY ESP” Ltd.;
2. Headquarters and address of management: Bulgaria, Sofia, Ovcha Kupel district, 52 Nikola Petkov Blvd., Trade House West, Office 1-08;
3. Address for exercising the activity: Bulgaria, Sofia, Ovcha Kupel district, 52 Nikola Petkov Blvd., Trade House West, Office 1-08;
4. Manager: Stefan Cavalino
5. Entry in public registers: UIC: 20547467
The Administrator collects and processes all personal data in accordance with the data protection laws applicable in the European Union.
GROUNDS FOR COLLECTION OF PERSONAL DATA
The Administrator collects and processes your personal data in connection with the use of the Site www.prolotherapyschool.com and the conclusion of contracts for online training with the Supplier pursuant to Art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:
• Explicit consent obtained from you as a customer / user. The consent obtained for the processing of personal data is voluntary and is provided on a case-by-case basis. The consent for the processing of personal data provided by you may be revoked at any time by submitting a Consent Withdrawal Form to the Administrator. Such a form can be found at the end of this section. The withdrawn consent is effective from now on, as it does not affect the legality of the processing of the personal data provided by you before the submission of the Withdrawal Consent Form;
• Fulfillment of the obligations of the Administrator under a contract with you;
• Compliance with a legal obligation that applies to the Administrator;
• For the purposes of the legitimate interests of the Administrator or a third party;
* For information security purposes.
PRINCIPLES FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA
The administrator follows the following principles when processing your personal data:
• legality, good faith and transparency;
• restriction of processing purposes;
• relevance to the purposes of processing and minimizing the data collected;
• accuracy and timeliness of the data;
• personal data is not used for profiling;
• personal data is not used for direct marketing;
• limitation of storage in order to achieve the objectives;
• integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.
WHAT DATA DO WE COLLECT FROM OUR USERS
Before accessing the services of the Site, you must express your explicit consent to the processing of your personal data in accordance with this Policy.
1. The Administrator shall not collect or store “sensitive” categories of personal data such as political beliefs, ethnic origin, sexual orientation, data on the subject’s health, religious or philosophical beliefs, etc.
2. Personal data collected by the person when the he contacts the Administrator through a contact form on the site.
When the person sends a message to the Administrator using the contact form, the Administrator collects and stores the name, telephone and e-mail address of the person, as well as the information provided in the message.
Purpose for which the data is collected: The administrator collects and stores the specified information for the purposes of communication with the individual.
3. Personal data collected automatically.
In our website we collect data for all visitors, namely:
• IP address;
• Browser ID;
• History of the pages you visit, in order to establish your preferences for certain types of content;
• History of your searches on our pages;
Purpose for which the data is collected: Improving the security of the services provided by the Supplier and preventing abuse of the use of the user account by third parties.
4. Personal data collected by users when ordering an online course:
• name and surname;
• email;
• address;
• telephone;
* data for debit / credit card through which the payment was made and data for the cardholder;
* Paypal account details,
• User’s bank details, such as IBAN, SWIFT code, user’s bank account number.
Purpose for which the data is collected: for the fulfillment of the obligations under the contract for sale of the online exchange rate, as well as for tax and accounting purposes
5. Personal data collected by the indivdual when the persons register on the site www.prolotherapyschool.com and data for receiving a newsletter. In the process of creating a user registration on the website, the creation of a unique password is required, as well as the provision of the following data:
• name and surname;
• email;
• address;
• telephone;
Purpose for which the data is collected: The data is collected and stored in order to identify the account holder and to assist the User in managing the account.
COOKIES
You can get more information about how the Administrator uses cookies by reading the Cookie Policy at www.prolotherapyschool.com
PURPOSES FOR PROCESSING PERSONAL DATA
The Administrator collects and processes the personal data of individuals, which are provided directly by them or are collected automatically only for the following purposes:
– For the normal functioning of all services on the Site;
– To make contact with the person;
– To provide services offered on the Site;
– To create an account and username in www.prolotherapyschool.com;
– the fulfillment of the rights and obligations of the parties to the concluded agreement;
– To improve the efficiency and functionality of the Site;
– For accounting purposes;
– For statistical purposes;
– For protection of information security;
– To send an information bulletin if you express a wish;
In the event of a change in the goals, we will inform you and ask for your explicit consent for the processing of your personal data in accordance with the new goals.
When processing and storing personal data, the Administrator may process and store personal data in order to protect the following legitimate interests:
* Fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal bodies.
HOW LONG DO WE STORE THE INFORMATION
We will not store your data for longer than necessary to achieve the purposes for which we process it. If the reason on which we store your personal data ceases to exist (for example, if we cease to have a legitimate interest in storing your personal data, if the statutory period for storing your personal data has expired or if you have withdrawn your consent to store your personal data), we will delete or destroy them in a safe way. The Company stores your personal data collected through the Site for a period not longer than necessary and / or due in accordance with the requirements of applicable law.
We apply the following terms for storing the different types of personal data according to their purpose, namely:
1. Regarding personal data of the persons who have made an inquiry, through the contact form on the Site:
– up to 1 year from sending the request, if the user has not become a client of the Administrator.
2. Regarding personal data collected when registering a user account on the site and receiving a newsletter:
– Until you wish your registration to be deleted or until www.prolotherapyschool.com operates.
3. Regarding the data in connection with the contractual relations between the Administrator and the User of the Site www.prolotherapyschool.com, they are stored for five years after the expiration of the limitation period for repayment of the public obligation to which they are related, unless the mandatory rules of law do not require the Supplier to keep the data for its partners for a longer period (eg for the categories of documents that we are obliged to keep according to the Accounting Act and / or the Tax and Social Security Procedure Code).
WHERE WE STORE YOUR PERSONAL DATA
We store or otherwise handle your personal information within the borders of the European Economic Area (EEA). We store your personal data for a period not longer than necessary to achieve the above objectives, or until the termination of the services and / or the Site. Your personal data collected through the Site will be collected, processed, stored, disclosed and destroyed in accordance with the applicable legislation of the EU and the Republic of Bulgaria.
SECURITY MEASURES
The administrator has taken a wide range of technical and organizational measures to protect your personal data against loss or other forms of illegal processing. All our employees are aware of our security policy provided for in the Personal Data Protection Act. The personal information of our Users is available only to a limited number of qualified employees. We regularly check our security systems and processes. Although we take reasonable steps to maintain a secure site, electronic communications and databases are subject to errors, tampering, and breaches, and we cannot guarantee that such events will not occur and we will not be liable to visitors for any such events.
We have procedures in place to respond to suspected data breaches. In case of suspicion of a breach of data security, we will notify both you and all relevant government institutions.
In case you want to receive detailed information about the technical and organizational measures, please do not hesitate to contact us.
PERSONAL DATA OF THIRD PARTIES
We process and use only data that you have provided to us voluntarily, and we rely on the fact that this data is owned and provided by you lawfully.
This means that each user is responsible for not providing the Administrator with data to third parties in violation of their rights to personal data protection.
Therefore, each person has unlimited personal liability if he provides us with data to a third party without his knowledge or without his consent in accordance with the requirements of applicable data protection law, regardless of the type of data or the reasons for which provide: names, phone, email address, and any other.
MINORS
If we receive information that we have collected personal data from / to a person under the age of 18, we will delete it immediately, unless we are legally obliged to store this data.
Please contact us if you believe we have inaccurately or unknowingly collected information from / under the age of 18.
TO WHOM WE SHARE AND DISCLOSE YOUR PERSONAL DATA
Sometimes we record some of the information on our servers or send it to third parties. This is necessary so that we can provide you with the best experience when using our services, and sometimes – in general, so that we can ensure the availability and accessibility of the service you use.
Your personal data will not be transferred to third parties unless:
– provide us with your explicit, informed and freely given consent;
– the third parties in question provide us with contractual support for the purpose of providing our products or services;
– this is required by law or by virtue of an act of authority of a public body;
– there is a justified need to protect the rights, property or security of users of the Site or other defensible public interest;
– this is required in connection with the sale of a business, our company or its assets, which are subject to confidentiality.
Our employees and partners are duly informed of the importance of their duty of confidentiality and are responsible for fulfilling this obligation.
For any other purposes not explicitly mentioned in this Policy, we will seek your explicit consent, identifying our partners as well as the purposes for the transfer and sharing of data.
LINKS, TOOLS AND CONTENT FROM OTHER COMPANIES
The site may contain buttons, tools or content that connect with other companies, such as Facebook, Instagram, Viber, Youtube, Vimeo and others. The administrator assumes no responsibility for damages and losses incurred as a result of the use of these sites. Individuals are solely responsible for their use of these sites and should read their Privacy Policies, as their privacy policies may differ from ours.
RIGHTS OF PERSON UNDER GDPR
Right of access to your personal data. You have the right to request and receive confirmation from the Administrator whether personal data related to you are processed by sending a request in free text or by using the forms at the end of this section by email.
Right to correct personal data: if you find that the personal data we process about you is inaccurate, you have the right to have us correct this personal data. You may at any time correct or complete inaccurate or incomplete personal data relating to you by making a request to the Administrator by email, using our form or by request in free text.
Right to delete personal data (the right to be “forgotten”)
You have the right to request from the Administrator the deletion of part or all of the personal data related to you, and the Administrator has the obligation to delete them without undue delay when there is any of the following reasons:
– personal data are no longer needed for the purposes for which they were collected or otherwise processed;
– You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
– You object to the processing of personal data related to you and there are no legal grounds for processing to take precedence;
– personal data have been processed illegally;
– personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Administrator;
The Administrator is not obliged to delete personal data if it stores and processes:
– to exercise the right to freedom of expression and the right to information;
– to comply with a legal obligation requiring processing provided for in EU law or the law of the Member State applicable to the Administrator or for the performance of a task in the public interest or in the exercise of official powers conferred on him;
– for reasons of public interest in the field of public health;
– for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
– for the establishment, exercise or defense of legal claims.
In order to exercise your right to be forgotten, it is necessary to send by e-mail a request for deletion of your personal data, which the Administrator processes, by filling in a form or by request in free text.
Right to restrict processing: in certain circumstances, such as if you have doubts about the accuracy of your personal data or have objected to our legitimate purpose of processing your personal data, you have the right to request that we restrict the processing of your personal data until a solution is found. You have the right to ask the Administrator to restrict the processing of data related to you by sending us a request in free text or by using an email form when:
– dispute the accuracy of personal data for a period that allows the Administrator to verify the accuracy of personal data;
– the processing is illegal, but you do not want the personal data to be deleted, but only their use to be restricted;
– The controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or protection of your legal claims;
– You have objected to the processing pending verification of whether the legal grounds of the Administrator take precedence over your interests.
Right to data portability. If you have given your consent for the processing of your personal data or the processing is necessary for the performance of the contract with the Administrator, or if your data is processed in an automated manner, you may:
– to request from the Administrator to provide you with your personal data in a readable format and to transfer them to another Administrator;
– to ask the Administrator to directly transfer your personal data to an administrator specified by you, when this is technically feasible.
Right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint regarding the processing of your personal data by us with the relevant supervisory authority.
● The person has the right not to be the subject of a decision based solely on automated processing, including profiling, which has legal consequences for the data subject or similarly affects him significantly;
● Right to judicial or administrative protection in case the data subject’s rights have been violated.
You can exercise all rights by contacting us via email: info@prolotherapyschool.com We will contact you and introduce you in detail to the procedure for exercising your rights.
MAINTENANCE OF A REGISTER
We maintain a register of the processing activities for which we are responsible. This register contains all the information below:
The name and contact details of the administrator
The purposes of processing;
Description of the categories of data subjects and of the categories of personal data;
The categories of recipients to whom the personal data are or will be disclosed,
the envisaged deadlines for deleting the different categories of data;
Where possible, a general description of the technical and organizational security measures
Appendix № 1
Withdrawal form of consent for processing purposes
Your Name*: …………………….
Your email that you used on the Site *: …………………….
Feedback data (e-mail) *: …………………….
To
Name: ……….. Ltd.
UIC / BULSTAT: …………………….
Headquarters and address of management:
Phone:
E-mail:
Website:
I hereby withdraw my consent to the processing of personal data provided by me for the purposes of receiving a newsletter, advertising messages or other marketing materials, as I am aware of the conditions for withdrawal of consent in accordance with the Mandatory Information on the Rights of Persons of personal data on the Site.
In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:
Title: Commission for Personal Data Protection.
Headquarters and address of management: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Address for correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Phone: 02 915 3 518
Website: www.cpdp.bg.
Appendix № 2
Request to be “forgotten” – to delete personal data related to me
Your Name*: …………………….
Your email with which you registered or used for orders on the Site *: …………………….
Feedback data (e-mail) *: …………………….
To
Name: ……….. Ltd.
UIC / BULSTAT: …………………….
Headquarters and address of management:
Phone:
E-mail:
Website:
I ask that all personal data that you collect, process and store provided by me or by third parties who are related to me, according to the specified identification, be deleted from your databases.
I declare that I am aware that some or all of my personal data may continue to be processed and stored by the Administrator for the purposes of fulfilling his legal obligations.
In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:
Title: Commission for Personal Data Protection.
Headquarters and address of management: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Address for correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Phone: 02 915 3 518
Website: www.cpdp.bg.
Appendix № 3
Request for portability of personal data
Your Name*: …………………….
Your email with which you registered or used on the Site *: …………………….
Feedback data (e-mail) *: …………………….
To
Name: ……….. Ltd.
UIC / BULSTAT: …………………….
Headquarters and address of management:
Phone:
E-mail:
Website:
I ask that all personal data related to me that is collected, processed and stored in your databases be sent in XML format to:
e-mail: …………………….
Administrator – receiving the data: …………………….
Name: …………………….
Identification number (UIC, BULSTAT, registration number in the CPDP): …………………….
Email: …………………….
In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:
Title: Commission for Personal Data Protection.
Headquarters and address of management: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Address for correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Phone: 02 915 3 518
Website: www.cpdp.bg.
Appendix № 4
Request for correction of data
Your Name*: …………………….
Your email with which you registered or used on the Site *: …………………….
Feedback data (e-mail) *: …………………….
To
Name: ……….. EOOD
UIC / BULSTAT: …………………….
Headquarters and address of management:
Phone:
E-mail:
Website:
Please correct the following personal data that you collect, process and store provided by me or by third parties who are related to me as follows:
Data to be corrected:
…………………………………………..
Please correct as follows:
…………………………………………..
In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:
Title: Commission for Personal Data Protection.
Headquarters and address of management: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Address for correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Phone: +359 2 915 3 518
Website: www.cpdp.bg.
This Privacy Policy is effective as of 01.02.2021 and is in line with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation).
