Privacy notice

Lead by Example Foundation provides this Privacy Notice, because it processes personal data of individuals, who visit the Foundation’s website: https://zaprimer.org/ (The Website) use the contact form available on the Website and/or participate in initiatives and events of the Foundation.

Lead by Example Foundation values ​​the importance of the personal data it processes and strives to protect them. Maintaining trust in us is one of our top priorities and we respect the right of individuals to keep their personal information private.

When providing personal data to Lead by Example Foundation, please inform yourself about the conditions under which we process this personal data.

      I. Introduction

For the purpose of this Privacy Notice the Controller of personal data is Lead by Example Foundation,a non-profit legal entity carrying out activities for the public benefit, registered in the Commercial Register and the register of non-profit legal entities with ID 207095597, and having seat and registered address at Sofia 1766, 6, Olimpiyska Street (the „Controller“ or the „Foundation“).

      II. Personal data

By personal data we mean any information that allows the identification of an individual. The Foundation processes personal data that individuals voluntarily provide us when visiting the Website, making an inquiry through the contact form on the Website and/or when participating in the Foundation's initiatives and events.

The categories of personal data we collect and store about you include:

  1. Information when visiting the Website

Upon standard browsing of our Website and its menus, we receive information about you in the form of an information protocol with the following content:

  • the webpage that referred you to our Website;
  • IP address;
  • date and duration of the access;
  • the amount of transferred data;
  • information about the browser and the operating system you use.

      2. Information related to inquiries made through the contact form on the Website

In case you wish to send an inquiry through the contact form on the Website, you will be asked to indicate:

  • names, contact phone, news agency (employer) and email through which we will contact you if necessary to respond to your inquiry;
  • any other personal data voluntarily provided by you in your message.

The Foundation does not perform profiling or automated decision-making.

     3. Information related to participation in events and initiatives, (co)organized by the Foundation

In case you wish to register for participation in an event or initiative, (co)organized by the Foundation, you will be asked to indicate the following data in the registration form provided by us:

  • names, contact phone, email;
  • other data that may be requested through the registration form, such as the name of the organization you represent, profession, etc.

This data is necessary to identify you and to contact you in connection with the organization and conduct of the relevant event.

In cases where the event is recorded, we may process your video image, photo and/or voice. This data will only be collected and processed if we have received your explicit consent. 

The Foundation does not perform profiling or automated decision-making.

        III. Purposes and legal basis for processing data

The Foundation processes the data only for the purposes for which they were collected and does not use them for other purposes. The Foundation will not process personal data if there is no legal basis. If the purposes of the processing are changed, the Foundation will notify the individuals in advance. 

The information when visiting the Website is processed for the purposes of maintaining and protecting our Website and IT systems, to ensure their proper functioning, to limit and prevent any unauthorized access to our Website, incl. to protect against hacker attacks. In such cases the legal basis for data processing is our legitimate interest.

The information related to inquiries made through the contact form on the Website will be processed to answer your inquiries, as well as to establish and maintain communication with you. In such cases the legal basis for data processing is our legitimate interest.

The information related to participation in events and initiatives of the Foundation will be processed for the purposes of organizing and holding our events and to ensure your participation in them. In such cases the legal basis for data processing is your consent. The Foundation will also require your explicit consent in cases where the event is recorded.

        IV. Sharing of personal data

We declare that the personal data provided will be treated as confidential and will not be shared with anyone other than:

  • Persons within the Foundation’s structure to the extent and volume necessary for the performance of their functions and duties;
  • Professional well-known consultants with good reputation, including lawyers, insurers, auditors and/or other external professional consultants;
  • Service providers, including companies that provide products and services to the Foundation, such as IT service providers;
  • State and administrative bodies, including regulatory bodies, law enforcement bodies, public bodies and judicial bodies in the performance of their legal duties.

We will ensure that any provision of personal data is lawful and that appropriate and sufficient measures and safeguards are in place in relation to the processing and protection of personal data.

        V. International transfer of personal data

When transferring personal data outside the EU/EEA we will use appropriate transfer mechanisms to ensure that the transfer is in compliance with applicable data protection legislation. Such mechanism shall be transferring the personal data: (i) to a recipient in a country for which the European Commission has decided to provide adequate level of data protection; (ii) to a recipient that has executed the Standard contractual clauses approved by the European Commission, or (iii) another appropriate mechanism.

In all cases we will ensure that we have provided appropriate and proportional measures for technical and organizational data protection and risk mitigation, as well as we have performed the appropriate risk assessments when transferring your personal data outside the EU/EEA.

        VI. Security measures 

We implement and maintain adequate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. The security measures include measures to provide encrypted transmission of personal data, as well as to ensure ongoing confidentiality, integrity, availability and resilience of our systems. 

        VII. Data retention

Unless otherwise stated, the Foundation will retain personal data for as long as is necessary for the purpose for which it was collected or processed as required by applicable law. For further information on retention periods, you can send an inquiry to the email: contact@zaprimer.org.

      VIII. Data subject rights

You are entitled to the following rights in relation to your personal data:

  • Right to be informed: You have the right to be informed about the collection and use of your personal data.
  • Right to access: You have the right to view and request copies of your personal data.
  • Right to rectification: You have the right to request inaccurate, incomplete or outdated information to be updated or corrected.
  • Right to erasure (“to be forgotten”): Under certain circumstances, you have the right to request your personal data to be deleted.
  • Right to data portability: You have the right to ask for your data to be transferred to another controller or provided to them (if technically feasible) in a machine-readable electronic format.
  • Right to restrict processing: Under certain conditions, you have the right to request the restriction of the processing of your personal data.
  • Right to withdraw consent: You have the right to withdraw your given consent to the processing of your personal data, where we rely on your consent as a legal basis for processing.
  • Right to object: Under certain conditions you have the right to object to the processing of your personal data (e.g. where we are relying on our legitimate interests as a legal basis for processing).
  • Right to object to automated processing: You have the right to object to decisions being made with your data solely based on automated decision making or profiling.

You can exercise any of your rights by submitting a request to the following email address: contact@zaprimer.orgWe will review and address your request within one month as of the date of receipt. Please note that if your request is particularly complex or you have made a number of requests, it may take us longer than a month to respond to you. In this case, we will notify you and keep you updated. Please note that we may ask you to provide us with additional information necessary to verify your identity prior to our response. However, in certain circumstances such as to comply with the applicable legislation, we may be unable to honor your request, for which you will be duly notified.

           IX. Data protection authority

You have the right to direct questions or lodge a complaint about the processing of your personal data at any time with the competent supervisory authority for data protection in the Republic of Bulgaria:

Personal Data Protection Commission

Address: 2, Tsvetan Lazarov Blvd., 1592 Sofia

Email: kzld@cpdp.bg kzld@cpdp.bg 

Website: https://www.cpdp.bg/

           X. Contact information

In case you have any questions regarding the processing of your personal data by us, please contact us at the following contact details: 

Lead by Example Foundation, 

Address: 6, Olimpiyska Street, 1766 Sofia

e-mail: contact@zaprimer.org 

Adopted on: 08.11.2023