Privacy Policy of Bulgaria Fund Management Company

Bulgaria Fund Management Company (“the Company”, “Controller”, “We”) recognizes the necessity of adequately protecting the personal data of data subjects (“You”, “Your”, “You”), and is committed to respecting your privacy. This Privacy Policy (“Policy”) is designed to help you understand how we collect, use, and protect your personal data, including when you agree to use our website.

For its activities as an Alternative Investment Fund Manager, the Company processes your personal data in strict compliance with Regulation (EU) 2016/679 (General Data Protection Regulation) (GDPR), the Bulgarian Personal Data Protection Act, other applicable regulations, and this Policy.

Definitions under the GDPR:

  • “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”).
  • “Processing” means any operation or set of operations performed on personal data or sets of personal data, whether by automated means or otherwise.
  • “Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • “Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
  • “Recipient” means a natural or legal person, public authority, agency, or another body to whom personal data is disclosed, whether a third party or not.

The Policy Provides Information Regarding:

  • Identification details of the Controller and contact information
  • Data subjects whose personal data is processed
  • Categories of personal data
  • Purposes for processing personal data
  • Legal grounds for processing personal data
  • Recipients of personal data
  • Retention periods for personal data
  • Rights of data subjects and how to exercise them
  • Consent and withdrawal of consent
  • Right to file a complaint with the supervisory authority
  • Personal data security measures

Identification Details of the Controller and Contact Information

The Controller of personal data is Bulgaria Fund Management Company located at: 4A Saborna St., 1st Floor, Sofia, Bulgaria; Email: office@aif.bg; Website: www.aif.bg; Phone: 00359 876 87 4445

Categories of Personal Data

If a potential client decides to place an order to subscribe to shares in an AIF managed by Bulgaria Fund Management Company, certain information will be requested. This information includes, but is not limited to, personal data such as:

  • Full name, national identification number, date and place of birth, ID card number and issuance date, address, phone number, email, bank account, income and its origin, citizenship and tax status information, photos, marital status, professional experience, and employment relationships.

The purpose of collecting this information is to identify the potential client and assess whether the requested service is appropriate before concluding a contract.

Special Categories of Data Processed

To comply with the Anti-Money Laundering Act, Bulgaria Fund Management Company collects and processes information that may include your political views (a special category of personal data under Regulation 2016/679). These personal data are collected based on a legal obligation, making their processing lawful by the Company.

Rights of Data Subjects and How to Exercise Them

Every client has the right to access the personal data collected about them by Bulgaria Fund Management Company. Clients may request:

  • Confirmation of whether data relating to them is being processed, information on the purposes of the processing, categories of data, and recipients to whom the data is disclosed.
  • Personal data in an understandable format.
  • Information on the logic of any automated processing of personal data.
  • The right to request deletion, correction, or blocking of personal data processed in violation of regulations.
  • The right to request a copy of personal data in a portable format.

Security Measures for Personal Data

Bulgaria Fund Management Company stores clients’ non-public information and personal data securely and confidentially. Access to personal data is restricted to employees handling the client account and those with control functions. All personal data is encrypted to ensure maximum protection.

Consent and Withdrawal of Consent

We may request consent from data subjects to process personal data for one or more specific purposes. Consent must be freely given, specific, informed, and unambiguous. Consent can be withdrawn at any time in the same manner it was given.

Right to File a Complaint

In accordance with the GDPR and the Bulgarian Personal Data Protection Act, data subjects have the right to file a complaint with the Commission for Personal Data Protection at: 2 Prof. Tsvetan Lazarov Blvd., Sofia, Bulgaria; Website: www.cpdp.bg.

Applicable Law

This Policy is governed by and interpreted in accordance with the laws of the Republic of Bulgaria. Disputes related to this Policy will be resolved between the parties or, if necessary, by the courts of the Republic of Bulgaria.

This Policy was adopted by the Board of Directors of Bulgaria Fund Management Company on March 24, 2023.