PERSONAL DATA PROCESSING AND PROTECTION POLICY
AND DECLARATION OF CONFIDENTIALITY
Sport Link LLC (the Company) shall hereby provide information about the personal data it processes, the reasons and the objectives of the processing, the recipients of these data, as well as any other information which is relevant to your personal data, pursuant to Article 13 and 14 of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 o n the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC .
The objective of this policy is to help you understand why and how we can use your personal data. Please read the policy carefully and in case that questions arise while becoming acquainted with it, do not hesitate to get in touch with us on the following email address: support@spotsscoreboard.com . The person responsible for the processing of the personal data is the Manager of the Company, Boris Brakalov.
Definitions
“ Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“ Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“ Controller” means one or more natural persons who determine the purposes and means of the processing of personal data where the purposes and means of such processing are determined by the European Union law or the law of the republic of Bulgaria.
“ Consent ” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
“ Customers” are data subjects, who may only be adult natural persons or representatives of legal entities, who have addressed Sport Link LLC in writing, orally or in the relevant electronic form with a request for provisions of services.
Information about the controller and contact details
Sport Link LLC, UIC: 202835218, seat and registered office address: Sofia 1504, 18 San Stefano Street.
Sport Link LLC considers the protection of the personal data of natural persons whose data it processes to be its main priority and undertakes to protect them in compliance with the procedures stipulated in the applicable national and European legislation.
What personal data do we process?
Within the meaning of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016: “Personal data” means any information relating to a natural person , by reference to which this person can be identified .
“ Sensitive personal data” are data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation . Sport Link LLC does not process sensitive personal data.
We may process personal data relating to you if you are:
А/ An employee of the Company or a person with whom the Company has concluded a part-time employment contract.
If this applies to you, Sport Link LLC usually processes the following personal data: identification data: first name, middle name, family name, date of birth, personal identification number, ID card data; contact details: email, address and telephone; education and/or qualification degree; professional experience, length of service and skills, bank account information.
For the time being Sport Link LLC does not process health data and other special categories of personal data (for example, information from fit notes, decisions of the Territorial Expert Medical Board (TEMB) and the National Expert Medical Board (NEMB), information provided by the occupational medicine service. However, it is possible that such data could be processed in the future, in the event of developing a medical condition for which you presented a fit note to the Company, a decision of TEMB/NEMB or other medical documentation. With regard to such information, D GREEN LTD shall apply special protection measures and shall process them on the grounds of its statutory obligation as an employer.
Other data required for the performance of obligations under fulltime or part-time employment relations (if applicable).
B/ A contractor or a representative of a contractor of the Company under a business or obligation contract or a person who wishes to enter into a contract with the Company.
If you are a party or a representative of a party to a contract concluded with the Company, including where the contract was not made in writing, but it is necessary to draw up documents under it, related to its execution or payments under it (for example, certificates of handover, receipts, invoices, etc.), the data of physical persons which are normally processed at Sport Link LLC in connection with the contract are:
In the case of a contractor who is a legal entity, which is represented by its legal representative: the legal representative’s, respectively, the financially responsible person’s, full name.
If the legal entity is represented by an authorised person: the full name of the legal representative acting as an authorising party and information about the authorised person, in line with the power of attorney presented.
In the event of occurrence of such, the data which shall be processed for the contractual party will usually be: full name, personal identification number, address, bank account for payment of amounts under the contract (if applicable).
Other data required for the conclusion and execution of the contract (if applicable).
C/ A customer of Sport Link LLC and user of the Internet pages supported by the Company described above – an adult natural person, in connection with the activity of the Company related to provision of services, including: provision of services related to development and granting the right to use mobile applications, computer programmes and products.
You may have a contract for provision of services concluded with the Company and in that connection you provide your personal data, such as: full name, address, personal identification number, number of your personal documents, telephone number, and email address.
You may be a user of the mobile application, which is property of the Company, by means of which the right to use services of the Company is granted, for which you provide your personal data, such as: full name, email address,.
D/ Representative of state control authority, performing an inspection of the operations of the Company.
If this applies to you, the data that we usually process are the data specified in the inspection record or the relevant formal note that you draw up: full name, position, contact details (if any provided).
For what purposes and on what grounds shall we use your data?
The personal data provided by you shall be used for the purposes specified below.
А/ If you are an employee of the Company or a person with whom the Company has concluded a part-time contract , your data shall be used for the purpose of administering the fulltime (part-time) employment relations.
Grounds: A fulltime/part-time employment contract concluded.
B/ If you are a contractor or a representative of a contractor of the Company under a business or obligation contract or a person who wishes to enter into a contract with the Company, your data shall be processed for the purpose of contract conclusion and execution.
Grounds: A contract concluded with the Company.
C/ If you are an adult natural person who is a customer of Sport Link LLC, your personal data shall be processed in connection with the activity of the Company related to provision of services, including: provision of services related to development and granting the right to use computer programmes and products. In connection with the services listed above, you provide your personal data to the Company, such as full name, personal identification number, address, ID document numbers, telephone number, email address.
Grounds: For the execution of the contract for provision of services to which you are a party.
D/ If you are an adult natural person who is a user of the mobile or desktop application, property of Sport Link LLC, namely: SPOTS Scoreboard in Google Play Store and Apple Store, and on http://spotsscoreboard.com, your personal data shall be processed in connection with the activity of the Company related to provision of services by means of the application referred to above, including: provision of services related to the right to use computer programs and products of the Company. In connection with the services listed you shall provide to the Company your device IP address, which will be recorded on the server electronic panel, which will remember the devices connected to it, so that next time it is run it will remember the settings of that device. Also, considering the need for a registration as a user of the application and following payments, you shall also provide your email address, or use one of the offered Single Sign-On (SSO) services.
E/ If you are representative of a state control authority, performing an inspection of the operations of the Company, the Company shall use the personal data provided by you for the purpose of carrying out the inspection, the enforcement or appeal of any formal notes made during or as a result of the inspection.
The legal grounds on which the Company processes your data are the following: statutory obligation and legitimate interest.
Who can we share your personal data with?
Sport Link LLC acknowledges and protects the confidentiality of your personal data. In observance of the legal requirements, it is possible for the Company to disclose your personal data to state and municipal authorities and institutions; Judicial authority bodies (court, prosecution, investigation, state and private bailiffs, public notary), experts appointed by the judge; banks. In execution of its legal obligations, the Company may be obligated to disclose personal data of persons whose data is processed by it. Such disclosure mat be required by a legal obligation or may come in response to an explicit instruction or request by state or municipal authorities or institutions in connection with or in regard to exercising their statutory functions or during any initiated inspection, audit, complaint, etc.
What period of time do we keep your personal data for?
Sport Link LLC shall store your personal data in compliance with the Policy storage, archive and destruction of documents at Sport Link LLC and the provisions of the applicable legislation. Your personal data shall only be kept by the Company for the period which is necessary for the fulfillment of the objectives for which the personal data were originally collected, unless a longer period of storage is stipulated for the Company by the law.
Example:
Documents which the Company control for the purpose of its business activity
contracts – until the expiry of the prescription periods for lodging claims and debt recovery, unless a longer period is provided for pursuant to the provisions of the current legislation or litigation is in process in connection with that;
records and formal notes from inspections and audits – 10 years as of 1 January of the year following the reporting period to which they refer, unless a longer period is provided for pursuant to the provisions of the current legislation.
Personal information security and privacy
Sport Link LLC shall maintain appropriate administrative, technical and organizational measures, intended to support the protection of the security and privacy of the personal data of persons whose personal data are processed by it, and to protect them from accidental or unlawful destruction, accidental loss, unauthorized correction, disclosure or access, misuse and any other illegal form of processing.
The data shall be recorded in a database which is properly protected by access password, encryption, and is stored on a secure server.
Your rights with regard to your personal data
In observance of the provisions of the current legislation, you have the following rights with regard to your personal data, controlled and processed by Sport Link LLC:
right of access to your personal data which are processed by the controller;
right to rectify any inaccurate or incomplete personal data;
right to erasure ( “right to be forgotten” ) of personal data which are unlawfully processed or there is no legal ground (expired storage period, withdrawn consent, fulfilled original objective for which they were collected, etc.);
right to restriction of the processing in the event of a legal dispute between the controller and the natural person until it is resolved and/or for the purpose of legal claims being ascertained, exercised or protected;
right to data portability – in the cases stipulated by the law, to make an objection, to exercise your right to data portability and request the provision of your data in a structured, commonly used and machine-readable format;
right to object to the processing of your personal data;
right of the data subject not to be subject to a decision based solely on automated processing, including profiling , which produces legal effects concerning him or her or similarly significantly affects him or her;
right to withdraw consent – in cases where the processing of your personal data is based on consent. The withdrawal of consent shall not affect the lawfulness of the processing based on consent in the period until the withdrawal of such consent;
right to lodge a complaint with the Data Protection Commission or the court.
You can lodge a complaint or bring attention in connection with the processing of your personal data with the Data Protection Commission, which has the following contact details:
Address: Sofia 1592, 2 Prof Tsvetan Lazarov Blvd.
Tel.: 02/915 35 18, 02/915 35 15, 02/915 35 19, fax: 02/915 35 25
E-mail: kzld@cpdp.bg
Website: www.cpdp.bg
Significance of the personal data provided.
With your consent, we process personal data when you voluntarily decide to receive information from us. You have the right to withdraw your consent at any time and this shall to discontinuation of sending of materials on our part.
For the purpose of financial and accounting reporting (invoice issue, keeping accounting information), we fulfil our legal obligations. Failure to provide your personal data in these cases prevents the issue of such documents.
How can you get in touch with us?
If you have any questions or complaints regarding this notification of confidentiality or the methods and the purposes for which we use your personal data, you can get in touch with us at the following address: Sofia 1750, Mladost 1 Residential Area, block No 11, entrance 3, floor 2, flat 74 and/or email: support@spotsscoreboard.com. Contact person: Boris Brakalov.
Data source
Sport Link LLC processes data which are provided to us by you.
In rare occasions it is also possible that we make use of information from publicly available registers (for example, the Commercial Register) or websites (for example, contact details available on the official websites of state offices and institutions).
Policy update
This policy may be updated regularly in order to include any changes made in personal date protection policies and practices applied at Sport Link LLC. The Company undertakes to inform you of any significant changes in the notification.