Data Protection Policy

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General Information

On 25 May 2018 the EU enforced a new General Data Protection Regulation. This regulation aims to ensure the protection of data of individuals from all EU Member States and to harmonize the regulations for their processing.

In its quality of Personal Data Administrator ANIDO Association meets all requirements of this new Regulation by collecting data of the persons insofar as this data is necessary for the provision of the services rendered by the Association and keeping it in a responsible and legal manner.

Information regarding the Personal Data Administrator

1. Name – ANIDO Association
2. BULSTAT: 131176595
3. Seat: Sofia City, Vitosha municipality, Metropolitan municipality, Knyazhevo district, 3 Byal Nartsis str.
4. Place of Business: Sofia City, Metropolitan municipality, Triaditsa District, 14 Alabin str., fl. 2
5. Mailing address: Sofia City, Metropolitan municipality, Triaditsa District, 14 Alabin str., fl. 2
6. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
7. Phone.: + 359 2 981 41 35
8. Name of the Data Protection Official: Ivan Yonkov Gatev
9. Mailing address: Sofia City, Metropolitan municipality, Triaditsa District, 14 Alabin str., fl. 2
10. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
11. Phone: +359 888 62 98 99

Information regarding the competent control authority

1. Name: Commission for Personal Data Protection
2. Seat and place for business: 1592 Sofia City, 2 Prof. Tsvetan Lazarov blvd.
3. Mailing address: 1592 Sofia City, 2 Prof. Tsvetan Lazarov blvd.
4. Phone:02 915 3 518
5. Email: This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it.
6. Website: www.cpdp.bg

ANIDO Association operates in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and the Council as of 27 April 2016 on the protection of natural persons 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) ANIDO Association collects and processes personal data provided by you in regard with our mediation activities in international adoption procedures in order to:

• • Providing specific information regarding your request
• • Preparing agreements and performing services as per this agreement.
• • Preparing and processing data contained in your dosser for submission to the Ministry of Justice of comprehensive information on your permission to adopt a child with a habitual residence in the Republic of Bulgaria and about your specific characteristics in this relation.
• • Implementation of the normative requirements of the Family Code, Ordinance No. 2/24.10.2014 on the terms and conditions for issuing and suspension of licences for mediation in international adoption and for granting approval by the Minister of Justice; the Convention of 29.05.1995 on Protection of Children and Co-operation in Respect of Intercountry Adoption, ratified by the Republic of Bulgaria.
• • Use of data collected for the implementation of the intercountry adoption procedure, including procedural representation, as well as post-adoption monitoring for two years as of the date the completion of the adoption procedure by the means of effective court ruling.
• • Implementation of statutory requirements of the Accountancy Act and other relevant normative acts.
• • Implementation of all activities related with the existence, amendment and termination of the contractual relations
• • Establishing contacts by phone, mailing address and/or email for correspondence related with the fulfilment of obligations under the agreements concluded by the Association.

(2) ANIDO Association follows the following principles for processing your personal data:

• legality, good faith and transparency;
• limitations for the purposes of processing;
• relevance to goals of processing and minimizing the collected data;
• accuracy and actuality of data;
• limited storage with a view to achieve goals;
• integrity and confidentiality of processing and ensuring suitable level of security of personal data.

What type of personal data is collected, processed and stored by ANIDO Association?

Art. 2. (1) ANIDO Association collects, processes and stores the following types of personal data about their clients:

1. 1. Related with physical identity: names, personal number, passport data, address, place of birth, contact phone numbers, etc.;
2. 2. Related with psychical identity, and in particular on mental health;
3. 3. Related with psychological identity, and in particular – documents related with their mental health;
4. 4. Related with economical identity, and in particular – data about property status;
5. 5. Related with cultural identity – interests, hobbies and other leisure activities;
6. 6. Related with family identity: marital status (married, divorced, number of members of the family, including children, etc.);
7. 7. Related with education: type of education, additional qualifications, etc.;
8. 8. Related with work experience – professional biography, data from labour book, etc.;
9. 9. Related with the civil status of the persons – criminal record clearance, parental rights clearance, etc.
10. 10. Contact phones, e-mails.

(2) ANIDO Association does not perform data-driven automated decision making.

Term of storage of your personal data

Art. 3. Personal data collected about you are stored for 5 years after the completion of the court proceedings and receipt of 4 post-placement reports, in compliance with the good court practice rules.

Your rights related with collection, processing and storage of your personal data

Withdrawal of consent for processing your personal data

Art. 4. In case you do not want some or all of your personal data to continue to be processed by ANIDO Association for any or all processing purposes, you may at any time withdraw your consent for processing by completing an online form or by requesting in your own words, as long as this does not contradict the current legal framework that regulates the adoption activity.

Right to access

Art. 5. (1) You are entitled to request and receive confirmation from ANIDO Association regarding whether they are processing your personal data.

(2) You are entitled to receive access to data related with this processing as well as to the information related with collection, processing and storage of your personal data.

(3) Upon request ANIDO Association shall provide you copy of your processed personal data in digital or other suitable form.

Right to correct or complete

Art. 6. Upon submission of a request to ANIDO Association, you may correct or complete inaccurate or incomplete data related with you

Right to deletion (“to be forgotten”)

Art. 7.(1) You are entitled to request ANIDO Association to delete the personal data related with you, and ANIDO Association is obliged to delete it without undue delay, upon any of the following justifications:

• your personal data are not needed anymore for the purposes it has been collected for or otherwise processed;
• You revoke tour consent which permits the processing of your personal data and there is no legal grounds for further processing;
• You object the processing of your personal data, including for direct marketing purposes, and there are no legal grounds for such a processing that prevail;
• Your personal data are not processed in a way that is in conformity with the current legislation;
• Your personal data need to be erased in order to comply with the legal obligation under EU legislation or State-Member legislation which applies to ANIDO Association;
• Your personal data has been collected in relation to provision of services to information society.

(2) ANIDO Association is not obliged to delete your personal data in case they store and process it:

• for executing the right of freedom of expression and right of information;
• for meeting a legal obligation which requires processing, stipulated by the EU legislation or State-Member legislation which applies to the Administrator or for performing a task of public interest, or upon executing official rights;
• on public interest reasons in the field of public health;
• for purposes of archiving in public interest, for scientific or historical studies or statistical purposes;
• for determining, executing or defense of legal claims.

(3) In order to exercise your right “to be forgotten”, you must submit a written request to ANIDO Association, as well as to prove your identity with the person the data are related to, as well as to present on site your ID card in order to identify yourself.

(4) ANIDO Association shall not delete data for which there are legal grounds for storage, including for defense regarding juridical claims towards ANIDO Association or for giving a proof of their rights.

Right to limitation

Art. 8. You are entitled to request ANIDO Association to limit the processing of data related with you in case:

• you contest the accuracy of your personal data for a time limit that allows ANIDO Association to verify the accuracy of your personal data;
• processing does not correspond to the current legislation, but you do not desire your personal data to be deleted but only to limit its usage;
• ANIDO Association does not need any more your personal data for the purposes of processing but you request it for determining, execution or defense of your legal claims;
• you have objected against the processing while expecting a verification whether the legal grounds of ANIDO Association prevail your own legal grounds.

Right to receive information

Art. 9. You may request ANIDO Association to inform you about any recipients to whom personal data requiring correction, deletion or restriction of processing has been provided. ANIDO Association may refuse to provide this information in case this would not be possible or would require disproportional effort.

Right to object

Art. 10. You may object to the processing of your personal data related to you by ANIDO Association, including if it is being processed for profiling or direct marketing purposes.

Your rights in cases of violation of your personal data privacy

Art. 11. (1) In case ANIDO Association detects a violation in your personal data privacy that may pose a high risk to your rights, we shall promptly inform you for this violation as well as for the measures undertaken or shall be undertaken.

(2) ANIDO Association is not obliged to inform you if:

• ANIDO Association has undertaken suitable technical and organizational security measures for the data affected by privacy violation;
• ANIDO Association has undertaken measures which guarantee that this porivacy violation shall not pose a high risk to your rights;
• This notification would require disproportional effort.

Persons that receive access to your personal data

Art. 12. The Administrator submits data to governmental authorities such as the Ministry of Justice – Central Authority under art. 16 of the Hague Convention, court, the Prosecutor’s Office, as well as other revising authorities – upon due request for this data in connection with exercising their powers.

Other provisions

Art. 13. In case of violation of your rights under the above or applicable data protection laws, you are entitled to file a complaint to the Commission for Personal Data Protection as follows:

1. Name: Commission for Personal Data Protection
2. Seat and place for business: 1592 Sofia City, 2 Prof. Tsvetan Lazarov blvd.
3. Mailing address: 1592 Sofia City, 2 Prof. Tsvetan Lazarov blvd.
4. Phone:02 915 3 518
5. Email: This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it.
6. Website: www.cpdp.bg

Art. 14. You may exercise all your rights related with the protection of your data through the forms enclosed to this information. Of course, these forms are not mandatory and you may make your claims in any form containing statement about it and identifies you as data holder.

Art. 15. In case the consent is related to a transfer, the Administrator shall describe the possible risks of personal data transfer to third states that provide no adequate protection.

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