Privacy policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors. and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal
data of our website visitors and service users; in other words, where we determine the
purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the
provision of our website and services, we will ask you to consent to our use of cookies when
you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Strategy Plus Business Lab. For more
information about us, see Section 13.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seglegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services ("usage data"). The usage
data may include your IP address, geographical location, browser type and version, operating
system, referral source, length of visit, page views and website navigation paths, as well as
information about the timing, frequency and pattern of your service use. The source of the
usage data is Google Analytics. This usage data may be processed for the purposes of
analysing the use of the website and services. The legal basis for this processing is consent OR
our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your information included in your personal profile on our website
("profile data"). The profile data may include your name, address, telephone number, email
address, interests and hobbies, educational details and employment details. The profile data
may be processed for the purposes of enabling and monitoring your use of our website and
services. The legal basis for this processing is consent OR our legitimate interests OR the
performance of a contract between you and us and/or taking steps, at you request, to enter
into such a contract OR your application to join the PrEXCELerator.
3.4 We may process your personal data that are provided in the course of the use of our
services ("Service data"). The service data may be processed [for the purposes of operating
our website, providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal basis for this
processing is consent OR our legitimate interests OR the performance of a contract between
you and us and/or taking steps, at your request, to enter into such a contract OR your
application to join the PrEXCELerator.
3.5 We may process information that you post for publication on our website or through our
services ("publication data"). The publication data may be processed for the purposes of
enabling such publication and administering our website and services. The legal basis for this
processing is consent OR our legitimate interests OR the performance of a contract between
you and us and/or taking steps, at your request, to enter into such a contract OR your
application to join the PrEXCELerator.
3.6 We may process information contained in any enquiry you submit to us regarding goods
and/or services ("enquiry data"). The enquiry data may be processed for the purposes of
offering, marketing and selling relevant goods and/or services to you. The legal basis for this
processing is consent.
3.7 We may process information relating to our customer relationships, including customer
contact information ("Customer relationship data"). The customer relationship data may
include your name, your employer, your job title or role, your contact details, and information
contained in communications between us and you or your employer. The source of the
customer relationship data is you. The customer relationship data may be processed for the
purposes of managing our relationships with customers, communicating with customers,
keeping records of those communications and promoting our products and services to
customers. The legal basis for this processing is consent OR our legitimate interests.
3.8 We may process information relating to transactions, including purchases of goods and
services, that you enter into with us and/or through our website ("transaction data"). The
transaction data may include your contact details, your card details and the transaction
details. The transaction data may be processed for the purpose of supplying the purchased
goods and services and keeping proper records of those transactions. The legal basis for this
processing is the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate interests.
3.9 The notification data may be processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this processing is consent OR the
performance of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.
3.10 We may process information contained in or relating to any communication that you
send to us ("correspondence data"). The correspondence data may include the
communication content and metadata associated with the communication. Our website will
generate the metadata associated with communications made using the website contact
forms. The correspondence data may be processed for the purposes of communicating with
you and record-keeping. The legal basis for this processing is our legitimate interests, namely
the proper administration of our website and business and communications with users OR
your application to join the PrEXCELerator.
3.11 We may process any of your personal data identified in this policy where necessary for
the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal rights and the
legal rights of others.
3.12 In addition to the specific purposes for which we may process your personal data set out
in this Section 3, we may also process any of your personal data where such processing is
necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
3.13 Please do not supply any other person's personal data to us, unless we prompt you to do
so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our professional advisers insofar as reasonably
necessary for the purposes of managing risks, obtaining professional advice, or the
establishment, exercise or defense of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.
4.2 Financial transactions relating to our website and services may be handled by our
payment services providers (Raiffeisenbank Bulgaria). We will share transaction data with
our payment services providers only to the extent necessary for the purposes of processing
your payments, refunding such payments and dealing with complaints and queries relating to
such payments and refunds. You can find information about the payment services provider’s
privacy policies and practices at https://www.rbb.bg/en/individual-clients/.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may
disclose your personal data where such disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data where such
disclosure is necessary for the establishment, exercise or defense of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 The hosting facilities for our website are situated in Bulgaria.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to
help ensure that we comply with our legal obligations in relation to the retention and deletion
of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
Newsletter subscriptions:
(a) Name, Surname, email address, job title will be retained until you unsubscribe.
Applications
(a) Name, Surname, email address, job title & other personal info you will disclose during the
application process will be retained for a maximum period of 5 years. If after applying for
a job, you do not want to be kept in our database, your data will be removed maximum 3
months after applying.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data
where such retention is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of another natural
person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this
policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law.
Some of the rights are complex, and not all of the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the processing, the categories
of personal data concerned and the recipients of the personal data. Providing the rights and
freedoms of others are not affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies may be subject to a reasonable
fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking
into account the purposes of the processing, to have any incomplete personal data about you
completed.
8.5 In some circumstances you have the right to the erasure of your personal data without
undue delay. Those circumstances include: the personal data are no longer necessary in
relation to the purposes for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing purposes; and the
personal data have been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for exercising the
right of freedom of expression and information; for compliance with a legal obligation; or for
the establishment, exercise or defense of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data.
Those circumstances are: you contest the accuracy of the personal data; processing is
unlawful but you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or defense of legal
claims; and you have objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your personal data.
However, we will only otherwise process it: with your consent; for the establishment, exercise
or defense of legal claims; for the protection of the rights of another natural or legal person;
or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to
your particular situation, but only to the extent that the legal basis for the processing is that
the processing is necessary for: the performance of a task carried out in the public interest or
in the exercise of any official authority vested in us; or the purposes of the legitimate interests
pursued by us or by a third party. If you make such an objection, we will cease to process the
personal information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the processing is for the
establishment, exercise or defense of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing
purposes (including profiling for direct marketing purposes). If you make such an objection,
we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or
historical research purposes or statistical purposes on grounds relating to your particular
situation, unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party
or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your
personal data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and freedoms of
others.
8.11 If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal will not affect
the lawfulness of processing before the withdrawal.
8.13 In case you don’t provide all mandatory application information in the Application Form,
we have the right not to admit you to the next stage of the application process.
8.14 In case you are not comfortable with providing your personal data for us to process in
the way as detailed herein, please do not provide them. Your personal data provision is
subject to your discretion, and serves the only purpose of your visiting and creating online
accounts at the web page of www.prexcelerate.eu. Your presumable refusal to provide your
personal data as may be needed for the purposes of serving your visits or online accounts at
our web site, shall be translated as a refusal to avail of such services of ours.
8.15 You may exercise any of your rights in relation to your personal data by written notice to
us OR by contacting us via sylviapavlova@spbusinesslab.com in addition to the other
methods specified in this Section 8].
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a
web server to a web browser and is stored by the browser. The identifier is then sent back to
the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be
stored by a web browser and will remain valid until its set expiry date, unless deleted by the
user before the expiry date; a session cookie, on the other hand, will expire at the end of the
user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information stored in and
obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you
navigate our website.
(b) analysis – we use cookies to help us to analyse the use and performance of our website
and services
(c) cookie consent – we use cookies to store your preferences in relation to the use of cookies
more generally.
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies maybe stored on your computer
when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers
information about website use by means of cookies. The information gathered relating to our
website is used to create reports about the use of our website. Google's privacy policy is
available at: https://www.google.com/policies/privacy/.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods
for doing so vary from browser to browser, and from version to version. You can however
obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies- website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet- explorer-delete-
manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and- privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by Strategy Plus Business Lab Ltd.
13.2 We are registered in Bulgaria under registration number …, and our registered office is
at Trakia Estate, bl.224A Plovdiv Bulgaria.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) by email: sylviapavlova@spbusinesslab.com.