Witmind Ltd., UIC 201316576 is a personal data controller and is engaged in the entire process of personal data protection and compliance with all requirements imposed by the LPPD and the European Regulation on Personal Data Protection (GDPR) / hereinafter “the Regulation”. /.

This Privacy Policy aims to inform and explain to you what personal data we collect and why, how and for what we use it, the conditions under which we provide it to third parties and for what purpose, the conditions for its storage and the applied measures for their security. .

The security policy of Witmind Ltd. may be changed and updated in order to ensure its compliance with the Bulgarian and mandatory for implementation in the Republic of Bulgaria European legislation.

In Witmind Ltd. the Personal Data Protection Officer is Zornitsa Todorova. You can contact him by e-mail: dataprotection@witmind.com or by phone: +359 2 44 33 040.

Who are we?

Witmind Ltd. is a high-tech company focused on IT and web solutions. The company has its headquarters and address of management in Sofia, 1 Vasil Petleshkov Str., Tel. +359 (2) 44 33 040, e-mail: office@witmind.com.

How do we collect personal data?

Personal data is collected personally by data subjects.

What data do we collect?

Personal data that we collect to carry out our activities are:

Ordinary personal data: names, PIN, address, telephone, e-mail, IP address, BULSTAT number (for self-insured persons);

In addition, employees and partners are collected ID card data, signature, bank account number, diploma data;

Special personal data of employees: health status (Sick leaves and conclusion of the Occupational Medicine Service).

For what purpose do we process personal data?

Personal data are processed only for official purposes, namely:

For concluding a contract – labor, civil or contract with a free profession and compliance with the requirements of labor and tax legislation;
To guarantee copyright and related rights to performances and works included in / co / produced or organized by Witmind Ltd. TV shows, concerts, albums and videos;
For issuing access cards;
For accounting purposes and payment of remuneration;
For concluding health insurance for employees;
For compiling waybills;
To make contact with users of the e-shop;
To make contact with contractors.

Fulfillment of a contractual obligation with a third party.


The data are stored for a different period of time depending on the requirements of current legislation:

The data of employees are stored for the terms according to the labor legislation, namely – 50 + 1 years from the date of concluding the contract;
Other accounting documentation containing personal data – 10 + 1 years from the date of preparation.
The data of persons holding copyright and related rights – six years from the date of expiration of the granted rights, and those who are not bound by a term – six years from the date of expiration of the term of protection; for contractors under civil contracts, who are not holders of rights under ZAPSP – six years from the date of termination of the contract; For the same period the data of the parents of minors, holders of rights under the Law on Copyright and Related Rights are kept;
Sensitive personal data – until the end of the calendar year in which the sick leave is issued and not more than 1 / one / month after the analysis of the health condition and the issuance of a conclusion for health fitness.
Data of other persons – for a period until the fulfillment of the respective goal, except in the cases when these persons request to be “forgotten”.

Who has access to your data?

We do not provide or sell personal data to third parties for marketing purposes.

Data are provided to NSSI, NRA and others. statutory recipients, when required by law;

For accounting services to a legal entity that performs such, in case of non-performance of a contract – to a lawyer or a law firm;

To the counterparties of Witmind Ltd. in the presence of a legal basis for providing the data or in the presence of the explicit consent of the data subject:

Contractors who provide services related to the activity of Witmind Ltd. – accounting firm – preparation of a statement of remuneration, preparation of an invoice for paid amounts, issuance of an official income statement under Article 50 of the Personal Income Tax Act and Article 45 of the Personal Income Tax Act, payments under contracts;
Insurance companies for services for the benefit of employees – issuance of health insurance;
Mobile operators for a contract for providing a business phone;
Occupational Medicine Service – data of employees for a conclusion on health fitness;
Counterparties requiring the provision of a certain amount of personal data under a contract;
The ISP and cloud service provider has access to IP addresses as well as databases of TV participants who have signed up to participate via web forms;
To a bank servicing Witmind Ltd. for the needs of payment of remunerations.


How do we store personal data?

Witmind Ltd. takes such technical and organizational security measures against unauthorized and illegal processing, accidental loss, destruction or damage of personal data as may be required, taking into account the state of technical development, common practice and legal requirements.

What are your rights?

You have the right to find out what is the privacy policy of Witmind Ltd. through this document.

You have the right to receive confirmation whether and what your personal data is processed, access to this personal data, as well as to receive a copy of the information on paper or electronic media (depending on technical capabilities).

You have the right to ask Witmind Ltd. to correct your inaccurate personal data without undue delay.

You have the right to request that your personal data be updated in the event of a change in it. Given the purposes of the processing, you have the right to have your incomplete personal data filled in, including by adding a declaration.

You have the right to request the deletion of personal data if the legal basis for their processing has ceased to exist or the data are not necessary for Witmind Ltd. to establish, exercise or defend against legal claims.

When there is no legal basis for the processing of personal data, you have the right to request a restriction on the processing of your personal data, as well as the right to object to the processing.

You have the right to request the transfer of your personal data to another Administrator.

You have the right not to be the subject of a solution based solely on automated processing, including profiling. Witmind Ltd. does not apply Automated decision-making, including profiling within the meaning of Article 22 of the Regulation.

You can exercise the rights specified in this section by sending your request (as well as the grounds for it) to e-mail: dataprotection@witmind.com as “Witmind” Ltd. will ensure the exercise of your rights related to personal data protection within the time limits. and in accordance with the terms of the Personal Data Protection Act and in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016.

Any person to whom personal data are processed under this policy has the right to appeal to a supervisory authority / CPDP or the competent Court / in connection with the processing of his personal data.

The provision of personal data by employees and contractors of Witmind Ltd. is a mandatory legal requirement. The provision of personal data to other data subjects is a contractual requirement. In case a data subject does not wish to provide his / her data, a contract cannot be concluded with him / her.

Review and supplement the Privacy Policy

This Privacy Policy is updated and / or supplemented periodically in the event of changes in the legislation of the Republic of Bulgaria or the EU.

The last update of the Privacy Policy is from May 2018.