Personal Data Protection Policy

General information

The new General Data Protection Regulation as adopted by the EU is applicable as from 25 May 2018. The Regulation aims to ensure the data protection of natural persons from all EU Member States and to harmonize the regulations for their processing.

As a controller of personal data, “ROSE OF THE HEART” Association meets all the requirements of the new regulation by collecting data of individuals to the extent necessary for the provision of the service and keeps them responsibly and lawfully.

Information about the Personal Data Controller

  1. Name – “ROSE OF THE HEART” Association
  2. BULSTAT/UIC: 177112205
  3. Registered address: 1233 Sofia, residential quarter Banishora, bl. 16, entrance A, floor 2, ap. 5;
  4. Correspondence data: 1233 Sofia, residential quarter Banishora, bl. 16, entrance A, floor 2, ap. 5
  5. E-mail: office@roseadoption-bulgaria.com 
  6. Mobile phone: +359-2-831-47-40
  7. Name of the personal data protection officer: Lilia Georgieva Karagecheva
  8. Correspondence data: 1233 Sofia, residential quarter Banishora, bl. 16, entrance A, floor 2, ap. 5
  9. E-mail: lilly@roseadoption-bulgaria.com 
  10. Mobile phone: +359 882 435 262

Information on the competent supervisory authority

  1. Name: Commission for Personal Data Protection
  2. Residence and address management: 1592 Sofia, 2 Professor Tsvetan Lazarov Blvd.
  3. Correspondence data: 1592 Sofia, 2 Professor Tsvetan Lazarov Blvd.
  4. Telephone number: 02 915 3 518
  5. E-mail: kzld@government.bgkzld@cpdp.bg
  6. Websitewww.cpdp.bg

ROSE OF THE HEART Association operates in accordance with the Personal Data Protection Act and 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.

Grounds for collecting, processing and storing your personal data. Goals and principles.

Art. 1. (1) “ROSE OF THE HEART” Association collects and processes personal data that you provide us in connection with our mediation in international adoption procedures with the purpose of:

  • Providing specific information in connection with your request.
  • Preparation of contracts and performance of contract services.
  • Preparation and processing of the data contained in your personal record in order to submit to the Ministry of Justice comprehensive information about your permission to adopt a child with habitual residence in the Republic of Bulgaria and about your specific characteristics in this regard.
  • Fulfillment of the legal requirements of the Family Code; Ordinance № 2 / 24.10.2014 on the Terms and Conditions for Issuing and Revoking a License for Mediation in Intercountry Adoption and for the Implementation and Termination of the Activities of Accredited Organizations; Ordinance № 3 / 24.10.2014 on Determining the Conditions and Procedure for Keeping the Registers for Intercountry Adoption and for Giving Consent by the Minister of Justice; The Convention for the Protection of Children and Co-operation in Respect of Intercountry Adoption of 29 May 1995, ratified by the Republic of Bulgaria.
  • Use of the collected data in order to implement the intercountry adoption procedure, including procedural representation, as well as post-adoption monitoring within two years from the completion of the adoption procedure with the court decision that has entered into force.
  • Fulfillment of the legal requirements of the Accounting Act and other relevant legislation.
  • Implementation of all activities related to the existence, amendment and termination of the contractual relationship.
  • Establishing a connection by phone, address and / or e-mail, for sending correspondence related to the fulfillment of obligations under the contracts concluded with the Association. 

(2) “ROSE OF THE HEART” Association observes the following principles in the processing of your personal data:

  • legality, good faith and transparency;
  • limitation of processing purposes;
  • relevance to the purposes of processing and minimizing the data collected;
  • accuracy and actuality of data;
  • 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 types of personal data does ROSE OF THE HEART Association collect, process and store?

Art. 2. (1) Association “ROSE OF THE HEART” collects, processes and stores the following types of personal data of its customers:

  1. Regarding physical identity: names, personal identifying number (PIN), passport data, address, place of birth, contact numbers, etc.;
  2. Regarding mental identity – and in particular on mental health;
  3. Regarding psychological identity – documents regarding their mental health;
  4. Regarding economic identity – and in particular: material status data;
  5. Regarding cultural identity – interests, hobbies and other leisure activities;
  6. Regarding family identity: marital status (presence of marriage, divorce, number of family members, including children, etc.);
  7. Regarding education – type of education, additional qualification, etc.;
  8. Regarding the labor activity – professional background, data about your job, etc.;
  9. Regarding the civil status of persons: criminal record, data on their parental rights, etc.
  10. Contact telephones, e-mail for establishing contact. 

(2) “ROSE OF THE HEART” Association does not perform automated decision-making with data.

Term of storage of your personal data

Art. 3. The personal data collected about you is stored for 5 years from completion of the court case and the receipt of the 4 post-adoption reports.

 

Your rights in the collection, processing and storage of your personal data

The right to withdrawal of consent for the processing of your personal data

Art. 4. If you do not wish all or part of your personal data to continue to be processed by the ROSE OF THE HEART Association for specific or all purposes of processing, you may at any time withdraw your consent to processing by filling out an online form or by request in a free text, as long as this does not contradict the current legal framework governing the adoption activity.

 

The right of access

Art. 5. (1) You have the right to request and receive from “ROSE OF THE HEART” Association confirmation whether personal data related to you is processed.

(2) You have the right to access the data related to you, as well as the information related to the collection, processing and storage of your personal data.

(3) “ROSE OF THE HEART” Association provides you with a copy of the processed personal data related to you, in electronic or other appropriate form.

The right to rectification or supplementation

Art. 6. You can correct or supplement inaccurate or incomplete personal data related to you by requesting “ROSE OF THE HEART” Association.

The right to erasure (“right to be forgotten”)

Art. 7. (1) You have the right to request from “ROSE OF THE HEART” Association deletion of personal data related to you, and “ROSE OF THE HEART” Association has the obligation to delete it without undue delay, when any of the following grounds:

    • personal data is no longer needed for the purposes for which the data was collected or otherwise processed;
    • You have withdrawn 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, including for the purposes of direct marketing and there are no legal grounds for processing to take precedence;
    • personal data has 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 applicable to the ROSE OF THE HEART Association;
    • personal data has been collected in connection with the provision of information society services. 

(2) “ROSE OF THE HEART” Association is not obliged to delete personal data if it stores and processes:

  • to exercise the right for freedom of expression and the right for information;
  • to comply with a legal obligation requiring processing, provided in the EU or Member State law, applicable to the Controller or for the performance of a task in the public interest or in the exercise of official powers conferred on him or her;
  • 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;
  • to establish, exercise or defend legal claims.

(3) In order to exercise your right to “be forgotten”, you should submit a written request sent to “ROSE OF THE HEART” Association, as well as to verify your identity with the data subject by presenting on the spot your identity card for identification purposes.

(4) “ROSE OF THE HEART” Association does not delete the data that it has a legal obligation to store, including for protection in connection with court claims against the Association or proof of their rights.

The right to restrict processing

Art. 8. You have the right to request ROSE OF THE HEART Association to limit the processing of data related to you when:

  • challenge the accuracy of personal data for a period that allows ROSE OF THE HEART Association to verify the accuracy of personal data;
  • the processing is illegal, but you do not want your personal data to be deleted, only its use to be restricted;
  • ROSE OF THE HEART Association no longer needs personal data for the purposes of processing, but you require it to establish, exercise or defend your legal claims;
  • You have objected to the processing pending verification of whether the legal grounds of ROSE OF THE HEART Association take precedence over your interests.

The right to be informed

Art. 9. You can request ROSE OF THE HEART Association to inform you about all recipients to whom the personal data has been disclosed, for which correction, deletion or restriction of processing has been requested. ROSE OF THE HEART Association may refuse to provide this information if this would be impossible or would require disproportionate enormous efforts.

The right to object

Art. 10. You may object at any time to the processing of personal data by the ROSE OF THE HEART Association that relates to you, including if it is processed for profiling or direct marketing purposes.

Your rights in the event of a personal data breach

Art. 11. (1) If the ROSE OF THE HEART Association finds a personal data breach, which may pose a high risk to your rights and freedom, we will notify you without undue delay of the breach and of the measures taken or are about to be taken.

(2) The ROSE OF THE HEART Association is not obliged to inform you if:

  • has taken appropriate technical and organizational protection measures with regard to data affected by the security breach;
  • has subsequently taken steps to ensure that the personal data breach does not pose a high risk to your rights;
  • notification would require a disproportionate effort.

Persons to whom your personal data is provided

Art. 12. The Controller submits data to state bodies such as the Ministry of Justice – Central Authority within the meaning of Article 6 of the Hague Convention for the Protection of Children and Cooperation in the Field of International Adoption, court, investigation, prosecutor’s office and other audit bodies – upon request of the data in due course and in connection with the exercise of their powers.

 

Other provisions

Art. 13. 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 Commission for Personal Data Protection as follows:

  1. Name: Commission for Personal Data Protection
  2. Residence and address management: 1592 Sofia, 2 Professor Tsvetan Lazarov Blvd.
  3. Correspondence data: 1592 Sofia, 2 Professor Tsvetan Lazarov Blvd.
  4. Telephone number: 02 915 3 518
  5. E-mail: kzld@government.bg, kzld@cpdp.bg
  6. Website: www.cpdp.bg

Art. 14. You may exercise all your rights to the protection of your personal data in any form that contains a statement to that effect and identifies you as the data holder.

Art. 15. If the consent relates to a transfer, the controller shall describe the possible risks of data transfer to third countries in the absence of a decision on adequate protection and appropriate remedies.

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