Contact Us: +359 877 967 555

Privacy Policy

"TERK" Ltd., with Unified Identification Code (EIK) 206118979, registered office and management address: Sofia, Sofia, 96 Tsarigradsko Shose Blvd. ("the Company"), is a data controller, within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (Regulation (EU) 2016/679), and the Personal Data Protection Act (PDPA).

This Privacy Policy provides information on how "TERK" Ltd. processes the personal data collected or received from its partners, employees, clients, and contractors, through forms filled in by you personally or by our representative, through email correspondence, contract conclusion, or other methods allowed by law for collecting personal data, as well as the data collected in the Internet space through our website www.thetopdentaledu.com.

Our contact details are as follows:

Sofia

Tel.: +359 877 967 555

Email: education@thetop.dental

Through this policy, we inform you about our practices regarding the protection of your data, your rights concerning the personal data collected about you through our website and/or collected by us through the other methods mentioned above.

If you have any questions, you can contact us and request information from our employees.

In collecting and processing your personal data, our Company complies with a number of laws and regulatory rules that dictate how these actions should be carried out, for what purposes, and what guarantees for the protection of personal data should be applied. The relevant regulatory framework includes, but is not limited to, Regulation (EU) 2016/679 of the European Parliament and of the Council 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 and repealing Directive 95/46/EC (Regulation (EU) 2016/679), PDPA, and other regulatory acts, as well as subordinate regulatory acts issued on their basis.

Basis for collecting, processing, and storing your personal data.

Article 1. The Administrator collects and processes your personal data in connection with the use of the online store/website www.thetopdentaledu.com and in connection with the conclusion and execution of contracts with the company on the basis of Article 6(1) of Regulation (EU) 2016/679, specifically based on the following grounds:

Explicit consent obtained from you as a client; Performance of the Administrator's obligations under a contract with you; Taking steps at your request to conclude a contract if you are a job candidate with us; Execution of a contract or taking steps to conclude such a contract with a commercial partner; Compliance with a legal obligation applicable to the Administrator; For the legitimate interests pursued by the Administrator or a third party.

Purposes and principles for collecting, processing, and storing your personal data

Article 2. We collect and process the personal data that you provide to us in connection with the use of the online store/website www.thetopdentaledu.com and the conclusion of a contract with the company, including for the following purposes:

Creating a profile and/or submitting an application and providing full functionality when using the online store; Individualization of the contracting party; Accounting purposes; Statistical purposes; Information security protection; Ensuring the performance of the contract for the provision of the relevant service; Sending newsletters and emails with special offers upon your express request; Sending responses to inquiries submitted through the feedback form on our website or by email.

Article 3. (1) When concluding a contract with a commercial partner, we collect and process personal data concerning the names of the legal representative of the legal entity – the contracting party, for the purposes of individualizing the contracting party and its performance.

(2) When concluding a contract with a partner – a natural person, we collect and process personal data concerning the full name, personal identification number, and data from an identity document (number, date of issue, issuer), for the purposes of individualizing the contracting party and its performance.

Article 4. (1) We collect and process the personal data that you provide to us when applying for a job in the Company, including for the following purposes:

  1. Individualization of the candidate;

  2. Contacting you and conducting communication;

Conducting candidate selection.

(2) We keep your personal data, which you have provided to us, for the entire duration of the job posting, and in case we wish to continue storing your data beyond this period for the purposes of subsequent communication with you, we will send you an email request to give your explicit consent for your data to continue to be stored for a specified period.

Article 5. We adhere to the following principles in processing your personal data:

  1. Legality, fairness, and transparency;
  2. Purpose limitation;

  3. Data minimization and relevance to the purposes of processing;

  4. Accuracy and timeliness of the data;

  5. Limitation of storage in order to achieve the purposes;

  6. Integrity and confidentiality of processing and ensuring an appropriate level of security of personal data;

Accountability.

Why we need and on what basis we use personal data

Article 6. The Administrator may process and store personal data in fulfillment of our regulatory obligations, such as:

  1. For conducting tax and social security controls by the relevant competent authorities or in fulfillment of tax and social security obligations;
  2. For issuing invoices and other accounting and/or reporting documents required by law;
  3. For providing information to competent state authorities.

Article 7. The Administrator may process and store personal data for the purpose of protecting its legitimate (legal) interests, such as:

  1. Processing inquiries and offering – based on taking steps at the request of the data subject before entering into a contract (Article 6, paragraph 1, (b) of Regulation (EU) 2016/679);
  2. Preparing proposals for entering into contracts and related documents, such as powers of attorney, securities, and others;
  3. Executing customer requests - based on contract performance (Article 6, paragraph 1, (b) of Regulation (EU) 2016/679);
  4. Execution of services and activities for the procurement of goods and services from suppliers - based on contract performance (Article 6, paragraph 1, (b) of Regulation (EU) 2016/679);
  5. Preparation, analysis, and storage of statistical information for internal company purposes related to financial analyses and reports;
  6. Personal data processed for the purposes of personnel selection;
  7. Personal data processed for the lawful exercise of the rights of partners in the company;
  8. Personal data processed when visiting our website.

Article 8. (1) Except in cases where we collect personal data based on law, contract, legitimate interest, or to protect your vital interests, we will request your consent.

(2) We will use your personal data only with your explicit consent for the specific purpose.

(3) You have the right, at a later stage, to withdraw your consent, which will not affect the lawfulness of processing based on your consent before its withdrawal.

(4) In cases where it is necessary to collect your personal data from you due to our legitimate interest or to protect your vital interests, we will inform you in a timely manner and explain your rights.

(5) You have the right to object to us collecting your personal data if you believe we do not have a legitimate interest in collecting them. We will take additional measures and provide you with additional information and our motives within 30 (thirty) days of your request.

What types of personal data our company collects, processes, and stores

Article 9. (1) The company performs the following operations with the personal data provided by you, for the following purposes:

  1. Registration of a customer in the online store/website and/or submission of an application as a participant/guest/lecturer at a training/course/event and execution of a distance selling contract – the purpose of this operation is to create a profile for using the online store to purchase goods and/or submit an application as a guest and provide contact information for delivering purchased goods.
  2. Registration and profile creation for using the online store are not obligatory steps for providing the service and are largely accessible without creating a profile through the "Order as Guest" option. Sending newsletters – the purpose of this operation is to administer the process of sending newsletters, emails with special offers, promotions, promo codes, news, and new features to customers who have requested to receive them.
  3. Exercising the right of withdrawal or filing a complaint – the purpose of this operation is to administer the process of exercising the right of withdrawal or filing a complaint by the customer for the goods for which these rights may be exercised.
  4. Sending inquiries through the feedback form on our website or by email – the purpose of this operation is to send a response to the inquiry.

(2) The Administrator processes the following categories of personal data and information about customers, for the following purposes and on the following grounds:

  1. Your identifying data (email address, name, etc.)
    • The purpose for which the data is collected:

      1. Establishing communication with the user and sending information to them.
      2. For the purpose of user registration in the online store and/or for submitting an application as a guest.
      3. For sending newsletters, emails with special offers, promotions, promo codes, news, and new features.
      4. Sending a response to inquiries through the website's form or by email.
    • The basis for processing your personal data – By accepting the terms and conditions and registering in the online store or placing an order without registration, or by entering into a written agreement between the Administrator and you, a contractual relationship is established, on the basis of which we process your personal data – Article 6, paragraph 1, letter (b) of Regulation (EU) 2016/679. Your data for sending newsletters and emails, as well as for sending a response to inquiries through the form on our website, are processed based on your explicit consent - Article 6, paragraph 1, letter (a) of Regulation (EU) 2016/679.
  2. Data for delivery purposes (names, phone numbers, addresses, etc.)
    • The purpose for which the data is collected:

      1. Fulfillment of the administrator's obligations under the purchase and sale contract and delivery of the purchased goods.
    • The legal basis for processing your personal data is as follows: By accepting the terms and conditions and registering in the online store or placing an order without registration, or by entering into a written agreement between the Administrator and you, a contractual relationship is established, on the basis of which we process your personal data – Article 6, paragraph 1, letter (b) of Regulation (EU) 2016/679.

(3) The Administrator does not collect or process personal data related to the following:

  1. Racial or ethnic origin;
  2. Political, religious, or philosophical beliefs, or membership in trade unions;
  3. Genetic and biometric data, data concerning health or data concerning a person's sex life or sexual orientation.

(4) The personal data are collected by the Administrator from the individuals to whom they relate.

(5) The Administrator does not conduct automated decision-making with data.

(6) The company does not collect data for individuals under the age of 16, except with the explicit consent of their parent or legal guardian.

Article 10. (1) The company performs the following operations with the personal data provided by you as job applicants, for the following purpose: entering into and executing an employment or civil contract.

(2) For the purpose of recruiting job candidates, we process the personal data that you have sent us in your resume.

(3) The Administrator does not collect or process personal data related to the following:

  1. Racial or ethnic origin;
  2. Political, religious, or philosophical beliefs, or membership in trade unions;
  3. Genetic and biometric data, data concerning health or data concerning a person's sex life or sexual orientation.

(4) The personal data are collected by the Administrator from the individuals to whom they relate.

(5) The Administrator does not collect and process data concerning the health status of job candidates, except after a selection process for the purpose of entering into an employment contract and determining suitable working conditions.

(6) The Administrator does not conduct automated decision-making with data.

Article 11. (1) The company performs operations with the personal data provided by you as legal representatives or agents of legal entities-commercial partners, including as individual partners, for the following purpose: entering into and executing a commercial transaction or contract with a client.

(2) For the conclusion and execution of a commercial transaction with a commercial company, we process only the three names of the legal representative or the authorized person appointed by the company, as well as for the individual partner under the contract.

(3) The personal data are collected by the Administrator from the individuals to whom they relate and from the Commercial Register at the Registry Agency.

Retention period of your personal data

Article 12. (1) The Administrator retains personal data of the customers of the online store for a period not exceeding the existence of your profile in the online store or the completion of the "guest" order. After deleting your profile or completing the order, the Administrator takes necessary measures to delete and destroy all your data without undue delay or to anonymize them (i.e., to render them in a form that does not reveal your identity).

(2) The Administrator retains your personal data provided in connection with online orders for a period of 5 years for the purposes of protecting the legal interests of the Administrator in legal or administrative disputes with users of the online store, with accounting documents being retained for the respective statutory period.

(3) The Administrator informs you in case the data retention period needs to be extended in order to fulfill a legal obligation or legitimate interests of the Administrator or other reasons.

(4) The Administrator retains personal data that must be kept under applicable law for the respective prescribed period, which may exceed the duration of your profile in the online store or the completion of the order.

Article 13. (1) The Administrator retains the personal data of the legal representatives of its commercial partners, the legal representatives of legal entities - parties to the contract, or the individual partners under the contract with the company for the term of the contract, to comply with the legitimate interests and legal obligations of the Administrator, which period may exceed the term of the concluded contract.

(2) The company retains your personal data as a job applicant for a period not exceeding the existence of a current job vacancy advertised on our website or elsewhere. After the expiration of the job posting or the completion of the selection process, the Company takes necessary measures to delete and destroy all your data without undue delay or to anonymize them (i.e., to render them in a form that does not reveal your identity), unless you give your explicit consent for your data to continue to be stored and processed for future purposes.

(3) The Administrator informs you in case the data retention period needs to be extended to fulfill a legal obligation or legitimate interests of the Administrator or other reasons.

Transfer of Your Personal Data for Processing

Article 14. (1) The Administrator may, at its own discretion, transfer part or all of your personal data to data processors for the purpose of fulfilling the processing objectives to which you have agreed, while complying with the requirements of Regulation (EU) 2016/679.

(2) The Administrator shall inform you in the event of the intention to transfer part or all of your personal data to third countries or international organizations.

Your Rights in the Collection, Processing, and Storage of Your Personal Data

Withdrawal of Consent for Processing Your Personal Data

Article 15. (1) If you do not wish all or part of your personal data to continue to be processed by the Company for specific or all processing purposes, you may at any time withdraw your consent for processing by submitting a request in free text.

(2) The Administrator may request you to verify your identity and the identity of the person to whom the data relates.

(3) By withdrawing consent for the processing of personal data that are mandatory for creating and maintaining a profile in the online store, your account will become inactive. Of course, you will still be able to browse the online store and the offered products and place orders as a guest or create a new registration.

(4) If you have placed an order that is in the process of being processed, the earliest moment at which you can withdraw your consent for processing is upon successful completion of the order.

(5) You may withdraw your consent for the processing of your personal data for the purposes of direct marketing at any time.

(6) Withdrawal of consent does not affect the lawfulness of processing of personal data carried out by the Administrator prior to that moment.

(7) The Company may continue to process all or part of your data if there is a legal obligation to do so or for the purposes of safeguarding its legitimate interests.

(8) Regarding legal representatives and physical persons-partners under contract with the company, paragraph 7 applies.

Right of access

Article 16. (1) You have the right to request and obtain from the Administrator confirmation as to whether personal data concerning you are being processed.

(2) You have the right to access the data concerning you, as well as information relating to the collection, processing, and storage of your personal data.

(3) Upon request, the Administrator provides you with a copy of the processed personal data concerning you, in electronic or another appropriate form.

(4) Access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in case of repetitiveness or excessiveness of requests.

Right to Rectification or Completion

Article 17. (1) You have the right to request from the Administrator to:

correct inaccurate personal data concerning you; complete incomplete personal data concerning you.

(2) If you are a registered user of the website, you may correct or complete inaccurate or incomplete personal data concerning you directly through your profile on the website or by sending a request to the Administrator.

Right to Erasure ("Right to be Forgotten")

Article 18. (1) You have the right to request from the Administrator the erasure of part or all of your personal data, and the Administrator has the obligation to erase them without undue delay when one of the following grounds applies:

  1. The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  2. You withdraw your consent on which the processing is based, and there is no other legal ground for the processing;
  3. You object to the processing of your personal data, and there are no overriding legitimate grounds for the processing;
  4. The personal data have been unlawfully processed;
  5. The personal data must be erased for compliance with a legal obligation under EU law or the law of a Member State applicable to the Administrator;
  6. The personal data have been collected in relation to the offer of information society services.

(2) The Administrator is not obliged to erase personal data if they are stored and processed for the following reasons:

  1. for exercising the right to freedom of expression and information;
  2. to comply with a legal obligation that requires processing, as provided for in EU law or the law of the Member State to which the Administrator is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Administrator;
  3. for reasons of public interest in the area of public health;
  4. for archival purposes in the public interest, for scientific or historical research purposes, or for statistical purposes;
  5. for the establishment, exercise, or defense of legal claims.

(3) In case you exercise your right to be forgotten, it will delete all your data, except for the following information:

  1. The information necessary to verify that your right to be forgotten has been fulfilled – email, IP address;
  2. Technical information about the functioning of the online store, which cannot be linked in any way to your identity;
  3. Email with which you registered on the online store (if you are a registered user of the site).

(4) In the event of exercising your right to be forgotten, the Company will delete all your data.

(5) The data of legal representatives and physical persons who are partners under contract with the company continue to be stored and processed, despite a request for forgetting being sent, based on compliance with a legal obligation of the company, for the protection of legitimate interests, and for establishing, exercising, or defending legal claims.

(6) To exercise your right to be forgotten, you need to send a request to "APOLLO" Ltd. in a manner convenient for you (by mail, courier, electronically with an electronic signature, in person, or through an authorized representative with a notarized power of attorney).

(7) The Administrator does not delete data that it is legally obliged to keep, including for protection against legal claims brought against it or for proving its rights.

The right to restriction of processing

Article 19. You have the right to request from the Administrator to restrict the processing of your personal data when:

  1. You dispute the accuracy of the personal data, for a period that allows the Administrator to verify the accuracy of the personal data;
  2. the processing is unlawful, but you do not want the personal data to be deleted, only to restrict their use;
  3. the Administrator no longer needs the personal data for the purposes of processing, but you require them to establish, exercise, or defend your legal claims;
  4. You have objected to the processing pending verification of whether the legitimate grounds of the Administrator override your interests.

Right to data portability

Article 20. (1) If you have consented to the processing of your personal data or if the processing is necessary for the performance of a contract with the Administrator, or if your data is processed automatically, you may, after legitimizing yourself to the Administrator:

  1. request from the Administrator to provide you with your personal data in a readable format and transfer them to another Administrator;
  2. request from the Administrator to directly transfer your personal data to the Administrator specified by you, when technically feasible.

(2) You can exercise your right to data portability by sending a free-text application.

Right to access information

Article 21. You may request the Administrator to inform you about all recipients to whom the personal data for which correction, deletion, or processing restriction has been requested has been disclosed. The Administrator may refuse to provide this information if it would be impossible or require disproportionate efforts.

Right to object

Article 22. You have the right to object at any time to the processing of personal data by the Administrator concerning you, including if processed for profiling or direct marketing purposes.

Your rights in case of a breach of the security of your personal data

Article 23. (1) If the Administrator identifies a breach of the security of your personal data that may pose a high risk to your rights and freedoms, they shall inform you without undue delay of the breach, as well as of the measures taken or to be taken.

(2) The Administrator is not obliged to inform you if:

  1. appropriate technical and organizational measures have been taken to protect the data affected by the security breach;
  2. subsequent measures have been taken to ensure that the breach will not result in a high risk to your rights;
  3. notification would require disproportionate effort.

Individuals to whom your personal data are disclosed

Article 24. For the purposes of processing your personal data and providing the service in its full functionality and in view of your interests, the Administrator may provide your data to the following personal data processors:

    • Persons maintaining software used for processing your personal data;
    • Consultants in various fields with whom "TERK" Ltd. has contractual relationships;
    • Banks processing payments to and from you;
    • Courier companies delivering goods, documents/correspondence to you;
    • Government authorities receiving your personal data under a legal act or having the right to request information about you from "APOLLO" Ltd.
     

Article 25. The Administrator does not transfer your data to third countries.

Exercising your rights

Article 26. (1) If you wish to exercise any of your rights or have questions regarding the processing of your personal data, please contact us using the contacts published on our website.

(2) You can exercise your rights by submitting a written request to "TERK" Ltd. in a way convenient for you (by mail, courier, electronically with an electronic signature, in person, or through an authorized representative with a notarized power of attorney).

(3) The request should contain the content specified in Article 37v of the Personal Data Protection Act, namely, it should include:

    • Name, address, personal identification number or personal identification number of a foreigner, or another analogous identifier;
    • Description of the request;
    • Preferred form of receiving information when exercising rights under Articles 15-22 of Regulation (EU) 2016/679;
    • Signature, date of submission of the application, and correspondence address.
     
     

(4) When submitting an application by an authorized person, the power of attorney shall be attached to the application.

(5) "TERK" Ltd. will consider your request/complaint, and within 2 (two) months of receiving it, you will receive a response. If necessary, this period may be extended by an additional month, taking into account the complexity and number of requests, for which you will be promptly informed, including the specific reasons for the delay.

(6) In cases under Article 54, paragraph 3, Article 55, paragraph 3 and 4, and Article 56, paragraph 6 and 7 of the Personal Data Protection Act, you can exercise your rights through the Commission for Personal Data Protection.

Right to appeal

Article 27. (1) If you believe that we are violating your rights, you may contact us to investigate the matter.

(2) In case of a violation of your rights under the applicable legislation for personal data protection, you have the right to file a complaint with the Commission for Personal Data Protection, using one of the following methods:

    • In person, on paper – in the registry of the CPDP at the following address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.
    • By mail – to the address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Commission for Personal Data Protection.
    • By fax – at 029153525.
    • By email to the CPDP email address (kzld@cpdp.bg). When submitting a complaint in this way, it must be in the form of an electronic document signed with a qualified electronic signature.
    • Through the Secure Electronic Delivery System maintained by the State e-Government Agency.
     
     

(3) Additional information can be obtained on the Commission's website - www.cpdp.bg.

Update/Revision

Article 28. (1) This Privacy Policy is regularly reviewed and updated by us to ensure maximum clarity, accuracy, and transparency, and to cover any changes that may arise with us (if necessary).

(2) The company may change the Privacy Policy by publishing a notice on its website.

The Privacy Policy was last updated on February 15, 2024.