Privacy Policy
Re-Act association is responsible for data processing
Nat. registration NUmber: 175841687
Fruzhin str. 4, Sofia 1000, Bulgaria
The data protection officer of Re-Act association is Lyuben Georgiev, luben@re-act.bg
We hereby inform you that we store and process your data (name, address, email address and telephone number). We only process other or sensitive data with your express consent. Data will also only be passed on to third parties with your prior consent. The data will only be passed on within the scope of the association’s purpose. An exception is any data passed on to the National Agency or the European Commission as part of your participation in our Erasmus+ and other mobility projects.
Your rights as a data subject:
Right to information, rectification, restriction of processing, objection, erasure, complaint and data portability:
You have the right to information about your processed personal data and the right to rectification at any time from the Re-Act association as the responsible party. If there is no statutory retention period or other legal basis for the processing of your data, you have the right to have this data deleted. If the processing is based on your consent, you have the right to revoke it. If the processing is carried out in the public interest or to protect the legitimate interests of the Re-Act association or third parties, you have the right to object to the processing. Furthermore, you may have the right to restrict processing, to data portability (if the processing is based on consent or contract execution) and to complain to the responsible supervisory authority.
Right of withdrawal
If your consent is required for the processing of your data, your data will only be processed by the Re-Act association after you have given your consent. You can revoke your consent – provided that the processing of your data is carried out exclusively on the basis of your consent – at any time at the following email address: contact@re-act.bg . The revocation of the consent does not affect the legality of the processing carried out on the basis of your consent up to the time of revocation. Statutory retention obligations are also not restricted by a revocation.
In principle, no data of minors is processed based on consent in accordance with Art. 6 Paragraph 1 Letter a of GDPR. By using the online services of the Re-Act association (website, newsletter, event registration), you confirm that you are at least 14 years old or that you have the consent of your legal guardian.
Contact details for exercising your rights
To exercise one of the rights mentioned in the previous points, please contact us at contact@re-act.bg or write to: Re-Act Association, Bulgaria, c/o Data Protection Officer Lyuben Georgiev, luben@re-act.bg
If you believe that your data protection rights have been violated, please also contact us at contact@re-act.bg or submit a complaint to the responsible supervisory authority (in Bulgaria this is the State e-Government Agency, Gen. Gurko 6 str., Sofia 1000, Bulgaria, email: milieva@e-gov.bg ).
ERASMUS
As part of your ERASMUS+ mobility, the Re-Act association collects data via a registration form and other forms that are needed to assess the possibility of participating in an ERASMUS+ mobility and, in case of positive participation, to report this to the National Agency and the Commission in the “Mobility Tool”.
The EU receives the following data via the “Mobility Tool”: name, first name, email address, gender, nationality, duration and type of mobility, main working language and any other languages used, and sending and hosting organisation. All personal data in the “Mobility Tool” are processed by the National Agency, the Executive Agency or the European Commission in accordance with the following legal provisions:
Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 1 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (Text with EEA relevance.)
In secondary order and only to the extent that Regulation (EU) 2018/1725 is not applicable – the General Data Protection Regulation (GDPR or Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 2 ) or national data protection rules if the GDPR is not applicable (non-EU countries).
If you transmit personal data of third parties (e.g. project partners, employees, other persons employed within the project, other persons participating in the project such as participants in events or surveys) to us in the course of the application or as part of your reporting and accounting obligations, you are obliged to inform the persons concerned about this data transfer and the data processing by the European Commission, Bulgarian National Agency (HRDC) and us.
These persons can assert their rights to information, rectification and restriction of processing by contacting us at contact@re-act.bg (see also section 4). However, the right to erasure and objection is excluded where the Research Organization Act (FOG) is applicable.
Your data will be passed on to the Bulgarian National Agency (HRDC) and then to assessors for the assessment of applications, interim and final reports in accordance with Section 2g FOG. Furthermore, in accordance with Art. 6 Paragraph 1 Letter f GDPR (our legitimate interest in checking the information provided by applicants and preventing misuse of funding), we may collect and transmit your personal data, even beyond the information you provide yourself, to assess whether the funding requirements are met and to check the billing, e.g. for credit checks with relevant credit agencies or to avoid double funding by making inquiries with the relevant EU and federal bodies or with other legal entities that award or process relevant funding or with other third parties.
It may also happen that your data must be passed on or disclosed in accordance with EU law, in particular to bodies and agents of the Court of Auditors, the Federal Ministry of Finance and the European Union.
For the purpose of assessing/reviewing applications and checking reports and accounts, your data may also be transmitted to scientific institutions, other funding and grant agencies and to reviewers in member states of the European Union.
The data processing is carried out on the basis of the Research Organisation Act, in particular Section 2g (processing by Art. 89 funding and grant agencies), Regulation (EU) No. 1288/2013 of the European Parliament and of the Council of 11 December 2013 establishing “Erasmus+”, the Union programme for general and vocational education, youth and sport, and repealing Decisions No. 1719/2006/EC, No. 1720/2006/EC and No. 1298/2008/EC”, in accordance with Art. 6 Paragraph 1 Letter b GDPR (initiation and execution of a contract) and Section 10a OeAD Act (mobility and cooperation database). The transfer of data to third countries is carried out on the basis of Art. 49 Paragraph 1 Letter b GDPR.
The data will be stored in accordance with Section 2g Paragraph 1 of the Federal Expropriation Law (FOG) and for the purpose of providing evidence to the Republic of Bulgaria as co-financing body for a period of at least ten years, namely
(a) in the event of withdrawal or non-pursuit of the application or a negative decision since the last contact and
b) in the event of a positive decision, from the end of the year in which the entire subsidy is paid out (= payment of the last installment by us after approval of the invoice or receipt of the repayment from you in accordance with our claim for reimbursement after the invoice)
stored.
For the processing pursuant to Section 2g Paragraph 1 Item 1 (retention period for funding documents) and 2 (publication on the Internet and in reports) as well as Paragraph 4 FOG (project information and information on persons involved in the project), the right to erasure pursuant to Article 17 Paragraph 3 Letter b GDPR and the right of objection pursuant to Article 21 Paragraph 6 GDPR are excluded from the time of the award of funding.
The data on mobility that must be transmitted to the mobility and cooperation database in the event of a funding award in accordance with Section 10a of the OeAD Act will be stored indefinitely. The right to erasure in accordance with Art. 17 Para. 3 Letter b GDPR and the right to object in accordance with Art. 21 Para. 6 GDPR are legally excluded here.
For the processing pursuant to Section 2g Paragraph 1 Item 1 (retention period for funding documents) and 2 (publication on the internet and in reports) and Paragraph 4 (project details and details of persons involved in the project), the right to erasure pursuant to Article 17 Paragraph 3 Letter b GDPR and the right of objection pursuant to Article 21 Paragraph 6 GDPR are excluded from the time of award of funding. Likewise, with regard to the mobility and cooperation database pursuant to Section 10a Paragraph 3 of the OeAD Act, the right to erasure pursuant to Article 17 Paragraph 3 Letter b GDPR and the right of objection pursuant to Article 21 Paragraph 6 GDPR are excluded.
Data protection declaration for the collection and processing of data for the reimbursement of travel expenses
We, Re-Act association, take the protection of your personal data very seriously. This privacy policy informs you about how we collect, use and protect your personal data in connection with the reimbursement of travel expenses.
Responsible body
Responsible for the processing of your personal data is:
Lyuben Georgiev, luben@re-act.bg
Type of data collected
To reimburse travel expenses, we require the following personal data:
Name: To verify your identity and correctly allocate payments, we need your full name.
IBAN (International Bank Account Number): In order to transfer the reimbursed travel expenses to your bank account, we need your IBAN.
Purpose of data collection and processing
Your personal data will be collected and processed solely for the purpose of reimbursing travel expenses in accordance with applicable legal provisions.
Legal basis for processing
The processing of your personal data for the reimbursement of travel expenses is based on Art. 6 Para. 1 lit. b) GDPR (execution of a contract).
Storage period
Your personal data will only be stored for as long as necessary to complete the refund process. Once the refund is complete, your data will be deleted.
Sharing of data
We will only share your personal data with third parties if this is necessary to process the reimbursement of travel expenses. This may include, for example, sharing it with our accounting department or banking partners.
Data security
We take appropriate technical and organizational measures to protect your personal data against loss, misuse or unauthorized access. We use encrypted connections (SSL) for the transmission of sensitive data.
Your rights
You have the right to information about the processing of your personal data as well as the right to rectification, erasure or restriction of the processing of this data. In addition, you can object to the processing of your data and exercise the right to data portability. Please contact us using the contact details provided below.
Contact
If you have any questions or concerns regarding data protection or would like to exercise any of your rights, please feel free to contact us:
Lyuben Georgiev, contact@re-act.bg
Update of the privacy policy
This Privacy Policy may be updated from time to time to reflect changes in our privacy practices.