This Privacy Policy has been prepared and is based on the Bulgarian legislation in force on personal data protection and Regulation (EU) 2016/679 of the European Parliament and of the Council from April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation).

Information about us:

SFB Capital Market AD (SFB), UIC 831414785, is the administrator of personal data,

address: Sofia 1000, 16-20 Alabin Str., phone: 02/980 10 86, fax 02/981 45 67,

e-mail: sfb@bia-bg.com

What are personal data and their processing?

Under the General Data Protection Regulation:

"Personal data" means any information relating to an identified individual or an individual that can be identified, directly or indirectly, by an identifier such as name, identification number, location data, online identifier or one or more signs specific to the physical, physiological, genetic, psychic, mental, economic, cultural or social identity of that individual.

"Processing" is any operation or set of operations performed with personal data or a set of personal data by automatic or other means such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, consulting, using, disclosing by transmission, distribution, or other means by which data becomes available, arranged or combined, restricted, deleted or destroyed.

What data is processed by SFB Capital Market JSC

1. Data provided by clients/users of SFB:

For orders of analyzes for development of the production, import and export for major sectors of the Bulgarian economy:

• names, telephone and/or e-mail, address/address for sending an invoice;
• data collected on payment made to the SFB in the manner specified in the Terms and Conditions at http://sfb.bia-bg.com;
• bank accounts;
• data required for invoice preparation and for proof of its reliability;
• information on payment method, payments made and due;
• IP address when visiting the website.

For inquiries for company reports:

• names;
• company, country, telephone, fax, e-mail;
• data collected on payment made to the SFB in the manner specified in the Terms and Conditions at http://sfb.bia-bg.com;
• bank accounts;
• data required for invoice preparation and for proof of its reliability;
• information on payment method, payments made and due;
• IP address when visiting the website.

2. Depending on the specific purposes and the reasons, SFB also processes public data not provided by the entity (individual) to which they refer, such as:

• names of owners, managers and representatives of Bulgarian private and state-owned enterprises, institutions and organizations;
• capital or shareholding.
• news and messages related to these subjects.

They are collected through the media and from official public sources of information about traders, associations and foundations, entered in the Commercial Register and the register of non-profit legal entities and subjects of the BULSTAT register.

3. Provided by subscribers of BIC electronic newsletters:

•    names;
•    e-mail

Personal data processing purposes:

Processing the data that is required for execution of a client request.

SFB processes data for the following purposes:

• Identify a customer/user when: executing inquiries for company reports and analyzes, providing information on explanations of the services used, paying the service;
• Updating the personal data or customer service information for customization/modification of data/services;
• Checking used services on request to protect clients of SFB from fraud and misuse by third parties;
• Sending a courier shipment with an original invoice for the payment made;
• Payments of analyzes and reports.

Processing of the data of the subscribers of the electronic publications of SFB in order to send the newsletters.

3. In fulfilling legal obligations, SFB processes customer data for the following purposes:

• Issuing of invoices and financial-accounting activity;
• To carry out tax and social control by the respective competent authorities;
• Implementation of the statutory requirements of the tax legislation: Accounting Act, Value Added Tax Act, Tax Insurance Code and others.

Categories of third parties accessing and processing personal data:

• Transport/courier companies in order to fulfill our contractual obligations to deliver contracts and invoices in paper form;
• Banks, servicing payments made by customers;
• Competent authorities, which, by virtue of a statutory acts, have the power to request from SFB the provision of information, including personal data: a Bulgarian court or a court of another country, different supervisory/regulatory bodies - the Commission for the Protection of Personal Data, protection of national security and public order.

Term for storing personal data

The duration of the storage of personal data depends on the processing purposes for which it was collected:

• Registration data (such as names, phone, email address) and information on making the registration and agreeing to the Terms and Conditions (date, time, IP address) are kept for the entire maintenance period and up to 1 (one) year of the registration termination.
• Personal data of the individuals taken from the Commercial Register (CR) are processed for statistical purposes and stored indefinitely. The publicity of the CR follows from the Commercial Register Act and Ordinance No 1 from 14 February 2007 on keeping, storing and accessing the Commercial Register. This publicity is bound by the legislator with the possibility of free access to facts and circumstances in the absence of the consent of the individual.
• Personal data processed for the purpose of issuing accounting/financial records for tax and social security controls such as invoices and others are kept for at least 5 years after the expiry of the limitation period for the repayment of the public claim unless the applicable law provides for a longer period .

Rights of SFB users/customers in relation to the processing of personal data

• Right of accessincludes: clear, transparent and comprehensible information about what personal data is being processed and information about the purposes and sources of such processing·        
• Right of correction and deletion: if the data processed are incomplete or wrong: to correct and delete personal data, news/messages, processing of which does not meet the requirements of the law
• Right of objection: at any time to be submitted:
• Right of objection:

(a) to the processing of personal data where there is a legitimate ground for doing so where the objection is justified, the person's personal data can no longer be processed.

• Right of limitation of processing: limiting the processing of customizable data if:

(a) the accuracy of the data shall be contested for the period during which its accuracy must be verified;

(b) the processing of the data is without legal basis, but instead of being erased, limited processing is required;

(c) where the customer needs them to establish, exercise or protect legal claims;

(d) An objection to the processing of the data was filed, pending verification that the reasons for the administrator are legal.

• Right to hide (limitation of public access): At the request of the representative of a legal entity/enterprise, subject of request for infomation, maydemand restriction of access to its data.
• Right to data portability: the user obtains the personal data he has provided and which relates to him/her in a structured, popular format adapted for machine reading, and to use this data for another administrator at his/her discretion.
• Automated making of individual solutions, including profiling: means that the user is not the subject of a decision based solely on automated processing involving profiling that produces legal consequences unless the applicable data protection legislation grounds for doing so and providing appropriate safeguards to protect your rights, freedoms and legitimate interests.
• Right to notify third parties. If applicable, request to SFB to notify third parties when it has provided your data with respect to the correction, deletion or limitation of the processing of personal data, except where this is impracticable or relates to excessive effort.
• Right of withdrawal: At any time to withdraw consent to processing of personal data, based on user consent. Such withdrawal shall not affect the lawfulness of the processing on the basis of the consent given until the withdrawal.
• Right of appeal: in case of breaches of the processing of personal data and of the applicable legislation by e-mail: bic@bia-bg.com or to the Commission for Personal Data Protection: address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Applications for the exercise of the stated rights of SFB users/customers in connection with the processing of personal data are filed in person or by an explicit authorized person through a power of attorney. An application may also be made electronically. The adjudication on the request is within 14 days of its submission. If a longer period is objectively necessary - in order to collect all the requested data and this seriously impedes the activity of SFB, this period may be extended to 30 days.

Using cookies

Purpose and use of cookies

SFB installs cookies only to allow the use or enhancement of functionalities and user navigation. In no case does SFB use cookies to collect, process, distribute or register personal information.

What does the user has to do if he/she does not want cookies installed on his computer?

Some people find that having a place to store information on a computer or mobile device is somewhat interfering, especially when this information is stored and used by unknown third parties. Blocking some or all cookies or removing cookies already placed on the user's device may result in some functionality being lost. This is done by changing the privacy settings of the browser it uses. Some third-party operators have developed tools to deactivate the collection and use of data from their modules.

The SFB site uses the following cookies:

PHP Session ID: This cookie is used to store navigation information.

language: This cookie is used to store the active language to properly redirect each page request.

The following cookies for Google are used on the SFB site:

__utma: This cookie lets you determine how many times a visitor came to the BIA site

__utmb: This cookie is used to know the duration of the site visit

__utmc: This cookie is used to know the duration of the site visit. Its term expires at the end of the session.

__utmz: This cookie lets you determine where the user came from on the site.

An additional module allows disabling Google Analytics (the page may not be available in the user's language).

This Policy is located at: http://sfb.bia-bg.com/privacyterms.php

SFB reserves the right at any time to amend and/or supplement this Policy. Changes take effect as soon as they are posted to the site. The policy can be updated at any time without specific notification to SFB users.

SFB is not responsible if a user does not know this policy.

Sofia, May 2018        
SFB Capital Market JSC