AirCom is dedicated to protecting the confidentiality and privacy of information entrusted to us. We comply with the EU General Data Protection Regulation (GDPR) and the Bulgarian data protection law. Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it. This website is operated by AirCom Bulgaria OOD, UIC 200553049, having its seat and registered address at ul. Okolovrasten pat 251, 621 vh.1 et.3 BG-1715 Sofia (“AirCom”, “we” or “us”), a Bulgarian limited liability company.
1. Who are we?
This Privacy Notice applies to AirCom EOOD, Uniform Identification Code 200553049 having seat and registered address at ul. Okolovrasten pat 251, 621 vh.1 et.3 BG-1715 Sofia.
2. Who can you contact for privacy questions or concerns?
If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to: AirCom, ul. Okolovrasten pat 251, 621 vh.1 et.3 BG-1715 Sofia or email info@AirCom.bg. We aim to respond within 30 days from the date we receive privacy-related communications.
If you are not satisfied with the response you receive, you may escalate your concern to our Privacy Liaison by sending an email to info@AirCom.bg. We will acknowledge your email within 14 days and seek to resolve your concern within 1 month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section below), or we may reject your concern on legitimate grounds.
In any event, you always have the right to lodge a complaint with the Commission for Personal Data Protection to report concerns you may have about our data handling practices at:
Postal address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
Telephone: +359 (2) 91-53-518
3. How do we collect personal data?
- Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host, visit our offices, apply for open positions at our companies or client’s organisations or provide reference for job applicants. For more information about personal data processing of job applicants, please read our Privacy Statement for job applicants. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
- Public sources -- Personal data may be obtained from public registers (such as Commercial Register), news articles, sanctions lists, and Internet searches.
- Social and professional networking sites -- If you register or login to our websites using social media (e.g., LinkedIn, Google, Facebook, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want to share with us.
- Business clients -- Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit and we often need to use personal data to provide certain advisory and other professional services. Our services may also include ○processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
- Suppliers, partners, subcontractors -- We may obtain personal data about representatives and contact persons of our suppliers, partners, and sub-contractors for the purposes of execution and performance of the relevant agreement.
- Recruitment services -- We may obtain personal data about candidates from an employment agency, and other parties including former employers and colleagues. For more information with regard to personal data processing of job applicants, please read our Privacy Statement for job applicants.
4. What categories of personal data do we collect?
We may obtain the following categories of personal data about individuals through direct interactions with us (e.g. if you choose to provide it — for example, to contact mailboxes or to register for certain services) or from information provided through client engagements, from job applicants, suppliers, partners, sub-contractors, and through other situations including those described in this Privacy Notice.
- Personal data. Here is a list of personal data we commonly collect to conduct our business activities.
- Identification information for contact purposes (e.g., names, company name, position details).
- Contact details (e.g., work and mobile telephone numbers, work and personal email and postal address).
- Professional details (e.g., job and career history, educational background and professional memberships, published articles).
- Personal data for the purposes of provision of professional services (e.g., name, personal identification number, date and place of birth, postal address).
- Personal data for the purposes of clients and ultimate beneficial owners identification as required by the applicable anti-money laundering law (e.g. name, place and date of birth, personal identification number, address, copy of ID documents).
- Family details for the purposes of provision of some professional services (e.g., names, personal identification number, date and place of birth).
- Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details).
- CCTV at our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
- Sensitive personal data. We typically do not collect sensitive or special categories of personal data about individuals. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes or if required by law. Examples of sensitive personal data we may obtain include:
- Dietary restrictions or access requirements when registering for in-person events that reveal religious beliefs or physical health.
- Personal identification documents that may reveal race or ethnic origin, and possibly biometric data of private individuals, beneficial owners of corporate entities, or job applicants.
- Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.
- Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
- Information provided to us by our clients in the course of a professional engagement.
- Child data. Although we do not intentionally collect information from individuals under 14 years of age, we may occasionally receive details about children attending performances and other events we host with their parents or guardians, or if such information is provided to us by our clients in the course of a professional engagement.
- Location-based data. We may process geographical locations you enter when seeking an office near you.
5. What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
- Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.
- Execution and performance of agreements with our suppliers, partners, sub-contractors, etc.
- Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
- Offering information and/or services to individuals who visit our website or offering information about employment opportunities.
- Customising individual’s online experience and improving the performance, usability and effectiveness of AirCom's online presence.
- Conducting and analysing our marketing activities.
- Meeting our corporate and social responsibility obligations.
- Preventing fraud or criminal activity and to safeguard our IT systems.
- Exercising our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.
AirCom does not normally carry out automated decision-making, including profiling, of personal data. If such is being carried out, AirCom undertakes to provide meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing. In some cases, the provision of personal data is a statutory requirement (e.g. as per Measures against Anti-money Laundering Act) and if the specific data is not provided we may be obliged to terminate the relations with our client. In other cases, the provision of personal data may be necessary to deliver agreed professional services and if the requested data is not provided we may be unable to perform our work. In addition, the provision of personal data may be voluntary, based on your explicit consent, and if the data is not provided we may not be able to perform the specific action requested by you (e.g. to send you a newsletter).
6. Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
7. Do we transfer your personal data?
7.1 Transfer within the global organisation of AirCom firms
We share information about you with other member firms of the AirCom global organisation as part of international engagements, and with AirCom and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the AirCom global organisation are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run AirCom’s business.
7.2 Transfers to third parties
We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
- Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
- Our professional advisers, including lawyers, auditors and insurers.
- A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger/acquisition of part or all of our business or assets, or any associated rights or interests.
- Payment services providers.
- Marketing services providers.
- Courts, law enforcement or other government and regulatory agencies and bodies (e.g., NRA, CPOSA) or to other third parties as required by, and in accordance with, applicable law or regulation.
8. Do we transfer your personal data outside the European Economic Area?
We store personal data on servers located in the European Economic Area (EEA). We may transfer personal data to AirCom, AirCom member firms, and reputable third party organisations situated inside or outside the EEA for the purposes described in this Privacy Notice. Each organisation is required to safeguard personal data as either the country where the organisation is located is considered an adequate country based on a Decision of the European Commission, or it is obliged by means of contracts we have in place with those organisations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission. You may find a complete list of adequate countries here. Upon request we will provide you with additional information about the data protection clauses we use.
10. What are your data protection rights?
Your data protection rights are highlighted here. In case you wish to exercise any of the rights described hereunder, you may use our template form (English version).
- Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if technically feasible.
- Automated Individual Decision-making – You can ask us to review any decisions made about you which are solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- Right to Object – You can object to our use of your personal data for direct marketing purposes, including profiling, or if we are not entitled to use it any more.
- Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case. You may withdraw your consent at any time by contacting us at 45/A Bulgaria Blvd., Sofia 1404, Bulgaria or info@AirCom.bg
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
11. What about personal data security?
11. What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
12. How long do we retain personal data?
We retain personal data to provide our services, receive services or goods from our suppliers and subcontractors, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained for more than ten years, unless otherwise required by law or for the establishment, exercise or defence of legal claims or dispute resolution. We will dispose of personal data in a secure manner when we no longer need it.
13. Do we link to other websites?
Our websites may contain links to other sites, including sites maintained by other AirCom member firms that are not governed by this Privacy Notice. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.
14. Do we change this Privacy Notice?
We regularly review this Privacy Notice and will post any updates to it on this webpage. When we make changes to this Privacy Notice, we will revise the "updated" date at the top of this page. This Privacy Notice was last updated 24 August 2023.
Any changes to the processing of personal data as described in this Privacy Notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.