This privacy notice outlines how and why the American University in Bulgaria (AUBG) collects, uses and stores your personal data, and your rights in relation to the personal data we hold. We may modify or amend this Privacy Notice. The most current version will always be available on our Website and, where appropriate, notified to you by e-mail. If you have any questions about such matters you can contact us at [email protected].
What personal data do we collect?
The personal information we collect from you is the following:
- your title, name (including maiden name), gender, date of birth;
- contact data including your home and business address, citizenship, email address and phone number;
- your business details including industry, position, organization; events you have attended;
- record of your meetings with AUBG representative(s);
- record of your financial donations;
- communication data including your preferences in receiving a certain type of communication from us.
How do we collect your personal data?
We collect information about you when you:
- attend or register for an AUBG fundraising event;
- make a donation to AUBG via an online payment (https://www.aubg.edu/donate/), bank transfer, check, or cash at the AUBG Business Office;
- sign a donation/ sponsorship contract.
From Third Party Sources:
- third party sources such as media articles, company and, charity filings or social network accounts (i.e. LinkedIn, Facebook, Twitter – depending on your privacy settings) or other public sources for example the world wide web.
Note: When we obtain personal data from third party sources, we will look to ensure that the third party has lawful authority to provide us with your personal data.
The basis for processing your information and how we use it
Receiving and processing your personal data, as detailed above is based on your consent and is exclusively used to provide the most appropriate opportunities to each friend of AUBG to support the work of the University, including determining your likely areas of interest.
AUBG will occasionally contact you by email, social media post and telephone to pursue the purpose mentioned above. The following type of communication will be sent to you:
- AUBG community updates;
- AUBG event invitations in Bulgaria and Abroad;
- AUBG Campaigns & Initiatives;
- Solicitation letters;
- Greeting cards.
We may further process your personal data for the following reasons:
- to process a gift you have given;
- register for event;
- to process and organize any volunteering activity you have agreed to undertake;
- to deal with any concerns or feedback you may have;
- to support our fundraising efforts;
- to promote our campaigns and initiatives happening on and off-campus.
We may also process your personal data in relation to compliance with our legal obligations. In this respect, we may use your personal data for the following:
- financial audits;
- compliance with our regulatory and legal obligations;
- compliance with anti-money laundering laws and safeguarding requirements;
- prevention and detection of crime;
- criminal investigations – assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- we have your specific or, where necessary, explicit consent to do so.
Control and care over your data
We, as an institution with one of the highest rankings in Bulgaria, are striving to improve and upgrade our control systems – to include pseudonymization of the collected and processed data, access controls, defined within the university, and most importantly – applied due care by our staff and faculty members. All measures are implemented against inadvertent or deliberate manipulation, loss, or destruction, and access by unauthorized persons
With whom we share your data?
Your data is held within the University and access to it is strictly controlled.
In cases when we are asked to facilitate the communications between individual donors, the aforementioned will be notified via email and asked for their written consent to do so. Unless permission is given, we will not release any personal contact details.
We may share your data with trusted third parties, including:
- Software providers whose technology allows us to fulfill our work (for example, Mailchimp, Blackbaud, Basno, Qgiv).
How long we keep it?
We consider our relationship with donors as ongoing and as such will maintain a record until you tell us you no longer wish to keep in touch or we have a requirement to delete information.
The American University in Bulgaria (AUBG) can implement mandatory COVID-19 testing as part of its measures to prevent/limit the spreading of COVID-19 on the territory of the University and with the aim to protect the life and health of its students, employees and visitors. The mandatory COVID-19 testing is based on the legitimate interest of the controller AUBG – Art. 6, p. 1, (f) of the General Data Protection Regulation (GDPR). Please note that the actual testing is carried out in licensed laboratories by medical practitioners and AUBG does not process personal data at that stage. Once presented with information about the medical status of individuals, the processing of this data by the University is based on Art. 9, p. 2, (b) of the GDPR – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
The AUBG has chosen tests that are most appropriate for the purposes of the testing and expenses for the tests are covered by the University. The AUBG will apply short retention periods by keeping the data related to the tests only for as long as it is necessary in order to make decisions connected with the purposes mentioned above: preventing/limiting the spreading of COVID-19 on the territory of the University and protecting the life and health of its students, employees and visitors. For your as a data subject in relation to the personal data we hold, please refer to the last section of this privacy notice.
Collection and use by third party vendors
We do not sell data or databases to third parties for any reason.
You rights in relation to the personal data we hold
- to request access to your personal data we hold;
- to rectify or erasure your personal data; to restrict or object to processing concerning your data;
- to request data transfer to other parties;
- to withdraw consent at any time, without affecting the lawfulness of processing based on consent before this withdrawal;
- to lodge a complaint with the supervisory authority – Commission for Personal Data Protection, address – 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.
You may address your concerns or inquiries to our Data Protection Officer (DPO) – Gugushev and Partners Law Office, Yoanna Ivanova, e-mail: [email protected]; Address: 11A Aksakov Street, floor 5, Sofia 1000, Bulgaria, Telephone: +359 2 815 75 10.
Please see AUBG Internal Rules for Data Protection for more information.