Toshev & Boteva takes your privacy very seriously. Please, read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
This privacy policy was last updated on 15th January 2019. We may further update this privacy policy from time to time, when we do so we will inform you on the home page of our website.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
“Toshev and Boteva” Law Office
Our data protection officer
Georgi Toshev
Personal data
Any information relating to an identified or identifiable individual
Special category personal data
- Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
- Genetic and biometric data
- Data concerning health, sex life or sexual orientation
Personal data we collect about you
Personal data we will collect
- Your name, address and telephone numbers;
- Information to enable us to check and verify your identity, e.g. your date of birth or passport details;
- Electronic contact details, e.g. your email address and mobile phone number;
- Information relating to the matter in which you are seeking our advice or representation;
- Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction;
- Information about your use of our IT, communication and other systems, and other monitoring information, e.g. if using our secure online client portal.
Personal data we may collect depending on why you have engaged with us
- Your National Insurance and tax details;
- Your bank and/or building society details;
- Details of your professional online presence, e.g. LinkedIn profile;
- Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter or a will;
- Your employment status and details including salary and benefits, e.g. if you instruct us on matter related to your employment or in which your employment status or income is relevant;
- Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g. if you instruct us on an immigration matter;
- Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship;
- Information to enable us to undertake a credit or other financial checks on you;
- Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g. if you instruct us on matter related to your employment or in which your employment records are relevant;
- Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on discrimination claim;
- Your trade union membership, e.g. if you instruct us on discrimination claim or your matter is funded by a trade union;
- Your medical records, e.g. if we are acting for you in a personal injury claim;
- Your image or likeness, e.g. captured during our seminars or events or as part of KYC documents.
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you. However, we may also collect information:
- from publicly accessible sources, e.g. Registry Agency Commercial Register and Register of NPLE or Land Registry.
- directly from a third party, e.g.:
- sanctions screening providers;
- credit reference agencies;
- client due diligence providers. - from a third party with your consent, e.g.:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer and/or trade union, professional body or pension administrators;
- your doctors, medical and occupational health professionals. - via our website—we use cookies on our website (for more information on cookies, please see our cookies policy;
- via our information technology (IT) systems, e.g.:
- case management, document management and time recording systems;
- door entry systems and reception logs;
- automated monitoring of our websites (such as Google Analytics) and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
How and why we use your personal data
Under Data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The information below explains what we use (process) your personal data for and our reasons for doing so:
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What we use your personal data for |
Our reasons |
|---|---|
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To provide legal services to you |
For the performance of our contract with you or to take steps at your request before entering into a contract; |
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Conducting checks to identify our clients and verify their identity |
To comply with our legal and regulatory obligations; |
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Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
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Ensuring business policies are adhered to e.g. policies covering security and internet use |
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you; |
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Operational reasons, such as improving efficiency, training and quality control |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price; |
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Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information; |
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Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price; |
|
Preventing unauthorized access and modifications to systems |
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you;
To comply with our legal and regulatory obligations; |
|
Updating and enhancing client records |
For the performance of our contract with you or to take steps at your request before entering into a contract;
To comply with our legal and regulatory obligations; |
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Statutory returns |
To comply with our legal and regulatory obligations |
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Ensuring safe working practices, staff administration and assessments |
To comply with our legal and regulatory obligations; |
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Marketing our services to:
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For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients; |
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Credit reference checks via external credit reference agencies |
For our legitimate interests or a those of a third party, i.e. for credit control and to ensure our clients are likely to be able to pay for our services; |
|
External audits and quality checks by auditors, regulators and providers of accreditation |
For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations; |
The information does not apply to special category personal data, which we will only process with your explicit consent.
Promotional communications
We may use your personal data to send you updates (electronically or by post) about legal developments that might be of interest to you and/or information about our services.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
Toshev & Boteva will always treat your personal data with the utmost respect and never sell it to or share it with other organizations to enable them to market to you:
You have the right to opt out of receiving promotional communications at any time by:
- contacting us by email (office@toshevboteva.com);
- using the ‘unsubscribe’ link in emails;
- updating your marketing preferences via the link found in any promotional email received from us.
Toshev & Boteva may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- professional advisers whom we instruct on your behalf or refer you to, e.g. lawyers, accountants, tax advisors, consultants, surveyors or other experts;
- other third parties where necessary to carry out your instructions, e.g. your mortgage provider or Land Registry in the case of a property transaction, Registry Agency Commercial Register and Register of NPLE or Land Registry;
- our group companies;
- credit reference agencies;
- our insurers and brokers;
- external auditors, e.g. in relation to the audit of our accounts;
- our banks;
- external service suppliers, representatives and agents we may use to make our business more efficient, e.g. typing services, marketing agencies, website hosts, providers of client relation management systems, document collation or analysis suppliers
- IT hosting services.
We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see 'Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available in our Information Retention, Destruction and Erasure Policy.
When it is no longer necessary to retain your personal data, we will delete or anonymize it.
Transferring your personal data out of the EEA
We may transfer your personal information to a location (for example to a secure server) outside the EEA, if we consider it necessary or desirable for the purposes set out in this policy. In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission adequacy decision applies (this is a decision from the Commission confirming that adequate safeguards are in place for the protection of personal data. See the list of such countries here, or will be carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, copies of which are available to view on the Commission’s website. We may also make such transfers with your explicit informed consent.
If you would like further information, please contact our Data Protection Officer (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
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Access |
The right to be provided with a copy of your personal data; |
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Rectification |
The right to require us to correct any mistakes in your personal data; |
|
To be forgotten |
The right to require us to delete your personal data—in certain situations; |
|
Restriction of processing |
The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data; |
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Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations; |
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To object |
The right to object:
|
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Not to be subject to automated individual decision-making |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Information and guidance from Commission for Personal Data Protection on individuals’ rights under the Law on Personal Data Protection and General Data Protection Regulation (for more information on personal data protection, please see https://www.cpdp.bg/?p=rubric&aid=4)
If you would like to exercise any of those rights, please:
- complete a data subject request form—available by emailing office@toshevboteva.com; or
- email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
- let us have enough information to identify you including full name, address and client or matter reference number if available);
- let us have proof of your identity and address (a copy of your ID card or Passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Toshev and Boteva Law Office has a robust and effective firewall and virus protection.
Access to our network:
- is restricted to permitted users;
- cannot be obtained through external storage devices;
- is not available to external users through our Wi-Fi systems.
Any data leaving our office on an external device is subject to an internal approval process and subsequent private encryption.
Further details can be made available on enquiry.
If you would like detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit https://www.safenet.bg or www.getsafeonline.org.
How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the BG is the Commission for Personal Data Protection.
How to contact us
Our contact details:
“Toshev and Boteva” Law Office
83 James Baucher Blvd., 2-nd floor, Office 6
Sofia 1164, Bulgaria
+359888330478 | office@toshevboteva.com
Our Data Protection Officer's contact details:
Georgi Toshev
83 James Baucher Blvd., 2-nd floor, Office 6
Sofia 1164, Bulgaria
+359888330478 | office@toshevboteva.com