Privacy Policy

Welcome to www.estat.bg

Thank you for visiting our website. We, ESTAT Ltd. (“ESTAT”, “we”, “our” or “us”), take your privacy seriously. We are committed to protecting the privacy of any personal information you give us. We will comply with the Bulgarian Personal Data Protection Act and all applicable regulations. We are registered on the public register of data controllers maintained by the Commission for Protection of Personal Data in Bulgaria.

Consent

We ask that you take the time to read this Privacy Policy carefully.  It explains a number of things including, for example, what personal information we collect on our website and the purposes for which we may use or disclose personal information.  By using www.estat.bg (the “Website”), however the Website is accessed and/or used by you (whether via personal computers, mobile devices or otherwise), you’ll be confirming that you have read and understood and agree to this Privacy Policy. 

When submitting request or question to the Website, you will be asked to provide certain information, such as name and email.  If you do not provide us with this information, we will be unable to answer your request or question.

If you do not agree with this Privacy Policy, please do not use the Website or submit the personal information required by us to assess any grant inquiry or application.

We may modify or amend this Privacy Policy from time to time without notice.  If we do, the most current version will always be available on our Website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Policy.  We will indicate at the top of this Privacy Policy when it was last updated.

Please be advised that the practices described in this Privacy Policy apply only to information gathered online at our Website.  They do not apply to information that you may submit to us offline or to websites maintained by other companies or organizations to which we may link.

What Information Do We Collect About You?

We will collect and process the following information about you:

  • Information you give us. This is information about you that you give us by filling in forms on the Website or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number.. 
  • Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:
  • Google Analytics: when you use the Website, we use analytics services provided by Google (“Google Analytics”) which collect and process information about your actual location and other technical information about your visit. The information collected by Google Analytics includes the Internet protocol (IP) address used to connect your computer to the internet, clickstream to, through and from our site (including date and time), and 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 cell towers.  For more information on how Google Analytics uses this information, please see the site “How Google uses data when you use our partners' sites or apps”, (located at google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).  Please refer back to this Google site for any changes or updates to these terms and the information collected by Google Analytics from time to time.

How and Why We Collect Your Information?

As a general matter, you can browse the Website without submitting your personal information to us.  However, there are a number of circumstances in which you may need to provide us with your personal information. 

We collect your personal information in the following ways:

  • When you make a request through “Contacts” menu;
  • When you participate in surveys, panels, or research;
  • When you request information or assistance;
  • In conjunction with your employment inquiries;
  • When you participate with social media accounts involving Foundation properties;
  • In conjunction with investigations into any activity that may violate the law or the Website’s terms and conditions;
  • When you communicate with us through the Website;
  • When you provide user-generated content on any part of the Website that permits it; and
  • In conjunction with any other place on the Website where you knowingly volunteer personal information.

When you interact with any ESTAT page or account on a social media platform, such as Facebook, Twitter, Google+, LinkedIn, Tumblr, YouTube, or Pinterest, or when you use your social media account or credentials to log in to the Website, we may also collect the personal information that you make available to us on that page or through that account, including your account ID or “handle.”

How Do We Use Your Information?

Our primary reason for collecting your information is to personalize your visits to the Website, to carry out our obligations arising from any contracts entered into between you and us and to notify you about changes to our organization and services.  In addition, we use your personal information in the following ways:

  • For editorial purposes;
  • Responding to your inquiries;
  • Communicating with you about changes to our policies;
  • Personalizing content and experiences on our Website, including providing you with recommendations based on your preferences;
  • Processing your employment application;
  • Event or program registration;
  • Optimizing or improving our programs, services, and operations;
  • Research and development;
  • Verifying your account and account activities;
  • Detecting, investigating, and preventing activities that may violate our policies or be illegal;
  • Performing statistical, demographic, and marketing analyses of users of the Website and their usage patterns; and
  • Managing our organization.

Where We Store Your Information

You expressly agree to our information practices, including the collection, use, processing, and sharing of your information as described in this Privacy Policy. You acknowledge that the laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country.

We won't retain your personal information for longer than is reasonably necessary or required by law.

How Do We Protect Your Information?

ESTAT is serious about guarding the security of your personal information.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.  We have strict security procedures covering the storage and disclosure of your information in order to prevent unauthorized access and to comply with the Bulgarian Personal Data Protection Act and all applicable regulations.This means that sometimes we may ask you for proof of identity before disclosing any personal information to you.

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Disclosure of Your Personal Information

ESTAT is committed to applying the highest standards of ethical and lawful practices in all our operations and is dedicated to protecting the privacy of all visitors to our Website.  Except as set out below, we will not sell, give away, or permit anyone outside the Foundation to use or access your personal information.

You agree that we have the right to share your personal information with selected third parties, including: (i) analytics and search engine providers that assist us in the improvement and optimization of our Website.  These third parties are contractually obligated to maintain the confidentiality and security of any personal information collected from the Website.  They are restricted from using, selling, distributing, or altering this information in any way other than to provide the requested services to us.

We will disclose your personal information in the cases and under the conditions prescribed by law.

Your Rights

You have the right at any time to access the information held about you. If you would like to make such a subject access request, please send us a letter at the following address: 9Sv. Sedmochislenitsi Street, floor 6, ap. 29, Sofia 1421, Bulgaria or send us an email to: office@estat.bgwith the words “Subject Access Request” in the subject line.

You are also able to challenge the accuracy and completeness of any recorded personal information that we hold about you and have it amended as appropriate, upon written notice to office@estat.bg

Cookie Policy

A cookie is a piece of information, like a tag, that is stored on your computer’s hard drive by your web browser when you visit a website.  As with many other online services, the ESTAT uses cookies (including in connection with the services provided by Google Analytics, as discussed above under “Information we collect about you”) to gather certain usage information such as how and when pages in the Website are visited, and by how many people.  You can set your browser to refuse, remove or block cookies or show when a cookie is being set up without affecting your use of most of the features of the Website.  For more information on cookies, please visit: www.allaboutcookies.org.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors to our Site and see how visitors use our Site. This cookie helps us to improve the way our website works.
  • Functionality cookies. These cookies are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences.
  • Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties may also use cookies, over which we have no control. [These cookies are likely to be analytical/performance cookies or targeting cookies]. If you do not want us to use cookies as we have outlined above, or if you change your mind after having consented to our use of cookies, you may delete and block cookies on this site via your browser. If you use your browser settings to block all cookies (including essential cookies) parts of our website may not work.

Policy regarding survey participation

ESTAT respects the following principles, which are explained in more detail later, concerning Personal Data and sensitive data and that they are:

  • Processed fairly and lawfully.
  • Processed for limited purposes and in an appropriate way.
  • Adequate, relevant and not excessive for the purpose.
  • Accurate.
  • Not kept longer than necessary for the purpose.
  • Processed in line with Data Subjects' rights.
  • Secure.
  • Not transferred to people or organisations situated in other countries without adequate protection.
  1. Lawfulness, Fairness and Transparency

Personal Data must be processed and collected lawfully, fairly and in a transparent manner in relation to the Data Subject. Furthermore, Data Subjects must be informed of how his/her data are being handled. In general, Personal Data must be collected directly from the individual concerned. Where this is not the case the legal basis on which the processing is nevertheless justified must be documented. The relevant DPO has to be consulted on whether a Data Protection Impact Assessment (DPIA) must be conducted (see also the separate guidance on DPIAs that can be found on the intranet.

  1. Purpose Limitation

Personal Data must only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Subsequent changes to the purpose are only possible to a limited extent and require substantiation and validation. The relevant DPO has to be consulted on whether a Data Protection Impact Assessment (DPIA) must be conducted (see also the separate guidance on DPIAs that can be found on the intranet.

  1. Data Minimisation

Personal Data must be adequate, relevant and limited what is necessary in relation for the purpose for which they are processed. It must be determined whether and to what extent the 6 processing of Personal Data is necessary to achieve the purpose for which the processing is undertaken. Where the purpose allows and where the expense involved is in proportion with the goal being pursued, anonymized data must be used instead of Personal Data.

  1. Accuracy

Personal Data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that Personal Data that are inaccurate, having regard for the purpose for which they are processed, are erased or rectified without delay.

  1. Storage Limitation

Personal Data must not be retained in a form which permits identification of Data Subjects for longer than is necessary for the purpose for which the Personal Data are processed. ESTAT will not keep Personal Data longer than is necessary for the purpose or purposes for which they were collected. ESTAT will take all reasonable steps to destroy, or erase from its systems, all Personal Data which are no longer required.

  1. Integrity and Confidentiality

Personal Data must be processed in a manner that ensures appropriate security of the Personal Data from being revealed, disseminated, accessed or manipulated. Therefore, where methodologically possible and the expense is not disproportionate to the Data Subject’s risks, pseudonymised data must be used for the processing – REMINDER: pseudonymised data remain and are Personal Data!

  1. Restriction on Transfers

Personal Data must not be transferred to other countries that do not offer an adequate level of protection. ESTAT has introduced various measures to adduce such adequate level of protection on a general basis, however, various countries may have further and/or different requirements that must be adhered to.

  1. General Measures and Considerations

Additionally in respect of its market research business ESTAT complies with the ICC/ESOMAR International Code on Market, Opinion, and Social Research and Data Analytics and Esomar’s Data Protection Checklist.

 

Legal Grounds for Data Processing

  • Consent to Data Processing

Respondents are the most common Data Subjects in ESTAT’s business. Consequently, the correct treatment of their Personal Data is at the heart of ESTAT’s business. Consent to Data Processing Personal Data can be processed following consent by the Data Subject. Before giving consent, the Data Subject must be informed in accordance with the transparency principle as set out under this Privacy Policy. The declaration of consent must be obtained in writing or electronically for the purposes of documentation. In some circumstances, such as telephone surveys, consent can be given verbally. In all cases, the granting of consent must be documented. Any consent will only be valid if it constitutes a freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which it giving a statement or by a clear affirmative action, signifies agreement to the processing of the Personal Data relating to him/her.

 

Rights of the Data Subject

Every Data Subject has the following rights. Their request is to be handled immediately by ESTAT and may not result in any disadvantage to the Data Subject.

  • Right of access: The Data Subjects may request information on which Personal Data relating to him/her have been stored, how the data were collected and for what purpose. If Personal Data are transmitted to 3rd parties, information must be given about the identity of the recipient or the categories of recipients.
  • Right to rectification: If Personal Data are incorrect or incomplete, the Data Subject can demand that they are corrected or supplemented.
  • Right to withdraw consent: Where the Personal Data are processed on the basis of Consent (see also the separate guidance on Consent), the Data Subjects can object to the processing at any time. These Personal Data must be blocked from the processing that has been objected to.
  • Right to erasure. The Data Subject may request his or her data to be deleted if the processing of such data has no legal basis, or if the legal basis has ceased to apply. The same applies if the purpose behind the data processing has lapsed or ceased to be applicable for other reasons. Existing retention periods and conflicting interests meriting protection must be observed.
  • Right to object: The Data Subjects generally has a right to object to his/her data being processed and this must be taken into account if the protection of his/her interest takes precedence over the interests of the data controller owing to the particular personal 13 situation. This does not apply, if a legal provision requires that the Personal Data are data to be processed. The employment agreements with
  • Right to data portability. The Data Subject has the right to request for the Personal Data provided by him/her to be made available to such Data Subject in a easily readable format, like a Word or Excel document.

 

Our Contact Details

If you have any questions regarding this Privacy Policy, complaints regarding the use of your information by ESTAT, if you would like to change your preferences, if you no longer wish to receive e-mail updates from ESTAT, or if you believe ESTAT has incorrect, outdated or incomplete information about you, please send an e-mail to: office@estat.bg