Confidentiality Agreement



Administrator data – WE:
CONTEMPORARY BOHEMIANS LTD., UIC 204194469, address: Bulgaria, Sofia 1527, 24 Vrabcha Str., Floor
2, e-mail:, is a limited liability company, whose main activity is
hospitality, catering, catering, food trade and all other kinds of goods.

Contact Data Protection Officer contact details:
CONTEMPORARY BOHEMIANS LTD. cooperates and has selected Mr. Yavor
Pavlov as its personal data protection officer, and you can contact him via the electronic
form for contacting us on our Internet page.

The personal data we collect and process from you are:
We provide you with information about us and our activities. In order to provide you with
additional information about our products, services, partners and any other information
than the one disclosed to our headquarters and management address and to our website in
order to respond to your inquiries and comments and in order to be in communication with
you, to collect your personal information so that we can identify you (if you wish) and
respond to your needs if and as much as we can. To achieve these goals, we collect
information about your names, e-mail, telephone, address, passport data, in volume you
provide us. We guarantee that the information we collect and use is indispensable for the
purposes stated and is not intended to enter your privacy and affect your personal interest
and privacy.

Special categories of data we process:
In view of the activity of CONTEMPORARY BOHEMIANS LTD. we do not process sensitive personal data to
our clients and partners.

The above personal data are obtained from you, in person or in some cases, by our trading
partners and / or other third parties.

We declare that the personal data we collect will be used for the following purposes:
Your personal data is necessary except to be in touch with you and to provide you with our
products and services as best as possible in time and in order to be able to perform other
statutory duties.

The basis that entitles us to process your data is:
– Processing is based on your consent;
– Processing your data is necessary to fulfill a contract with you or our intention to enter into
a contract;
– Processing is necessary to meet our legal obligation – Processing is necessary to protect
your (vital) interests (or other person's interests).

By agreeing to accept this Notice, you authorize us to process your personal data only for
the purposes we designate and, if necessary, provide you with explicit and written informed
Consent is necessary in order to process both types of (ordinary and special) personal data,
but it needs to be explicit.
You can withdraw your consent at any time with a letter sent to us, which can be obtained
from us on request or made available in free text.
Transmission of personal data to a non-EU country or an international organization:
“CONTEMPORARY BOHEMIANS” Ltd. does not intend to submit your personal data to third parties except
in the cases established by law.

We will not sell your data to third parties, nor will we pass it on to obtain any benefit. We
may provide your personal data to persons who assist us in achieving the above-described
purposes – processing personal data acting on a written contract in accordance with our
explicit instructions and applying appropriate technical and organizational measures to
protect your personal data. Personal data will not be shared with third parties nor shared
outside the European Union or the European Economic Area. Recipients of your data may
also be individuals and bodies with authority to whom we will provide them in accordance
with specific and clear legal obligations. When we intend to submit your special personal
data (if you have provided us) to a third party, we will do so only after we have received
your consent, except that we will have to do otherwise.

takes place

The personal data we collect and process: in case you are a visitor to our company at its
address or on a site that we have video surveillance with, we will process your image data
and behavior giving information about the human image and the characteristic traits, an
image of your behavior, habits, committed offenses and other visible information.
The source of this data is: We receive the above personal data from you, personally.
We declare that the personal data we collect in video surveillance will only be used for
legitimate purposes such as property security, security, safety and order protection, public
health protection, and prevention of theft and other abuses.

The grounds that give us the right to process your data for image and behavior are: our
legitimate interest in the implementation of security and security and public interest. In
addition to this, we can also make the lawful due assistance to competent public authorities
within the framework of the powers granted to them.

Processing time: We process your video surveillance data for up to 60 (sixty) days under the
Private Security Act. Usually this processing is limited to real-time monitoring of guarded
sites and storage of relevant records.

Total storage period
The personal data for clients of the company are kept for a period of up to 5 years from the
conclusion of the respective contract with the client. This period is in line with the limitation
period for the submission of any claims arising from the contract.

The personal data of job-seekers who are not approved for recruitment in the Company are
kept for the period defined by the current legislation in the field of personal data protection
from the end of the procedure, after which they are returned to the person or destroyed.
Personal data may be stored for a longer period in order to make suggestions for work only
with the consent of the applicant in writing.

Personal data about the employees of the company are kept according to the Bulgarian
legislation, until the expiry of the stipulated terms after the termination of the employment

Video surveillance recordings in the company are stored for up to 60 (sixty) days in
accordance with the Private Security Act. The personal data that the company collects in
video surveillance will only be used for legitimate purposes, such as property security,
security, safety and order in commercial sites, public health protection in food trade, and
prevention of theft and other abuses.

Personal data contained in accounting documents shall be kept in accordance with the
deadlines provided for under the Accountancy Act.

How we store and preserve your personal data we process:
We will process your personal data when undertaking necessary and sufficient technical and
organizational measures for their protection. Among other things, we have taken the
necessary internal policies and have taken steps to protect your personal data at the design
stage; data officers are well aware of the privacy requirements; the processing of your
personal data is limited to the minimum necessary to achieve the relevant goals; we have
implemented the necessary security measures, such as security, restricted access, security
systems, etc .; we have put in place measures to ensure permanent confidentiality, integrity,
availability and sustainability of processing systems and services, as well as measures in the
event of a physical or technical incident for timely recovery of availability and access to
personal data; an internal process for the regular testing, assessment and evaluation of the
effectiveness of technical and organizational measures has been put in place in order to
ensure the security of the processing; a procedure for storing and destroying data has been
developed. We will process (collect, store and use) the information you provide in a manner
consistent with the requirements of the General Data Protection Regulation (CRPD). We will
strive to keep the information accurate and current.
We do not make automated decision-making (without human intervention) in the
processing of your personal data for any of the above purposes.

Your rights as a data subject are as follows:

At any time while we store or process your personal data, you (according to the terminology
of the law – data subject) have the following rights:

• you have the right to request a copy of your personal data from CONTEMPORARY BOHEMIANS Ltd.  and the
right of access at any time to your personal data;
• You have the right to request from CONTEMPORARY BOHEMIANS Ltd. your personal data in a form
convenient to transfer to another data administrator or to ask us to do so without being
hindered by us;
• You have the right to ask CONTEMPORARY BOHEMIANS Ltd. to correct without undue delay your
inaccurate personal data as well as data that are not current;
• You have the right to request from CONTEMPORARY BOHEMIANS LTD your personal data to be deleted
without undue delay in any of the following circumstances:
o personal data are no longer needed for the purposes for which they were collected;
o when you have withdrawn your consent;
o when you have objected to the processing,
o when processing is unlawful;
o where personal data must be erased in order to comply with a legal obligation under EU
law or the law of a Member State that applies to us as a data controller;
o when personal data have been gathered in connection with the provision of information
society services.
We may refuse to delete your personal information for the following reasons:
o in the exercise of the right to freedom of expression and the right to information;
o to comply with a legal obligation on our part or to carry out a task in the public interest,
o for reasons of public interest in the field of public health;
o for purposes of archiving in the public interest, for scientific or historical research or for
statistical purposes, insofar as erasure is likely to make it impossible or seriously hindering
the attainment of the purposes of such processing; or for the establishment, exercise or
protection of legal claims.
• You have the right to request from CONTEMPORARY BOHEMIANS Ltd. to restrict the processing of your
personal data, in which case the data will only be stored but not processed. Our refusal to
restrict will be explicit only in writing, and we are obliged to motivate it for the legitimate
• You have the right to withdraw your consent to the processing of your personal data at
any time with a separate request addressed to the administrator;
• You have the right to object to certain types of processing, such as direct marketing
(unsolicited advertising messages);
• You have the right to object to automated processing, including profiling;
• You have the right not to be the subject of a decision based solely on automated
processing including profiling;
• If we need to use your personal data for a new purpose not covered by this privacy
statement, we will provide you with a new data protection notice and when and where
necessary we will require your prior consent for the new processing.
All the above requests will be forwarded if there is a third party (recipients, including
outside the EU and international organizations) in the processing of your personal data.

You have the right to appeal to the supervisory authority

You have the right to submit a complaint directly to the oversight body and the competent
authority is the Personal Data Protection Commission, address: Sofia 1592, "Prof. Tzvetan
Lazarov "№ 2 (
In case you wish to file a complaint about the processing of your personal data through CONTEMPORARY BOHEMIANS Ltd., you can do so on the contact details of CONTEMPORARY BOHEMIANS Ltd. or directly to the
Data Protection Officer of the above contact details.

Approved by:
Yavor Pavlov – Manager