General Data Protection Regulation (GDPR) Policy & Data Processing by ILC International

This privacy policy is intended to give you information about how and why ILC International LTD (from here onwards referred to as ILC International) processes personal data, as well as what your rights are in relation to receiving services as a customer and other relationships related to the marketing and management of ILC International. If you have any questions or would like to confirm how
ILC International processes any personal information, contact us at connect@ilc.one

I. INTRODUCTION
ILC International is a company that offers coaching services and services related to applied psychology with the following areas of expertise: performance coaching (focused on the unique problems of startups, founders and leaders); business training & team coaching; strategy development in regards to organizational psychology & performance measurements; performance consulting; performance mentoring; life coaching;

One of our top priority is to work ethically and responsibly, comply with legislation, including in the field of data protection, and meet your expectations towards the processing of it.

As professionals, we are trained and obliged to protect the confidentiality of our customers which is reflected in our individual contracts. As a company we adhere to the same high standards as well as GDPR requirements.

In order to manage and develop its activities, ILC International processes data in regards to the following main categories of data subjects:

-       INDIVIDUALS WHO ARE DIRECT CLIENTS OF ILC INTERNATIONAL
-       INDIVIDUALS SIGNED UP FOR MARKETING COMMUNICATION FROM ILC INTERNATIONAL
-       LEGAL AND / OR AUTHORIZED REPRESENTATIVES, AS WELL AS CONTACT PERSONS, OR ANY CORPORATE ORGANIZATION THAT HAS A CONTRACTUAL RELATIONSHIP WITH ILC INTERNATIONAL

II. HOW, WHY AND IN WHAT TIME-FRAME WE PROCESS YOUR DATA
This information applies both to 1/ the data subject that have provided data to ILC International, and 2/ to those whose personal data has been provided to ILC International by third parties.

ILC international LLC, EIC: 205545939, with headquarters and management address:
Sofia, Lozenets, 1, Persenk, app.3, the Republic of Bulgaria represented by Valentina Dolmova – Managing Director, processes personal data as follows:

INDIVIDUALS
ILC International may process the following categories of data from current or potential customers, and other persons who are interested in the marketing activities organized by us, and whose data would allow us to deliver that successfully.

* physical identity data:
may include first and last names; contact details (e.g. email, phone number or address).

* financial data:
may include bank details (if applicable)

LEGAL AND / ORAUTHORIZED REPRESENTATIVES, CONTACT PERSONS OR ANY CORPORATE ORGANIZATION THAT HAS A CONTRACTUAL RELATIONSHIP WITH ILC INTERNATIONAL
(referred to below as "counterparties“)

ILC international processes the following categories of personal data of its counterparties:

* the minimum amount of personal data required for signing any relevant agreements includes names and USN.

* personal information about an official contact during the course of the contract. This information is limited to the types of information that can be contained in any business correspondance: first and last name, position, employer's name, work address, work email address, and work phone number.

We receive from our counterparties such personal data (contact information) in regards to employees or other persons that our contractors have assigned to be contact persons, in accordance with the relevant agreement. The counterprties who provide us with such data are also personal data administrators in relation to the data in question, and are responsible for providing the relevant data subjects with all necessary information in this regard. Moreover, the counterparties are required to ensure the accuracy of this data and keep it up-to-date at all times. This means that if any data, provided to us, is no longer relevant, we should be duly notified as soon as possible. Until we receive such notification, we assume that our contact information is accurate and we may use it for the purposes described below.

We use personal data to establish your identity, to develop and improve our services, and to comply with the laws governing our activities. Below are all the purposes for which we may collect personal data as well as our reasons for it.

What we may collect personal  data for:
1) To know who you are

The nature of our work requires us to identify our clients. This means that we need to collect minimal personal information. (with client consent)

2) To enter into contractual  agreement(s) and fulfill it
Your personal data is processed in order for us to enter into and maintain a  contractual relationship, and it is our legal duty to store this data even  after the services are delivered.
(legal obligation & with client consent)

3) To improve and develop our services:
We want to ensure we provide our customers with high-quality services at all times. Based on client's needs we may want to develop new or improved offerings.
(business interest)

4) To fulfill the goals and  targets you have given your consent to:
In some cases, when another condition is not applicable, and to achieve a  specific business goal, we will need your consent to the processing of your data. If we need your consent, we will require it from you in a clear and transparent  way. You will be able to withdraw your consent and ILC International will stop processing your information for the relevant purpose.
(with client consent)

III. WHAT ARE YOUR RIGHTS:
If you are a person whose personal data is processed by ILC International, in any of the above circumstances, you have the following rights in this regard:

You can always ask if we process your personal data, and if we do, request information about what information we store, why, and how we process it. You also have the right to a copy of your data.

THE RIGHT TO CORRECT
We would like your personal data to be accurate and up-to-date. If any part of your data is inaccurate or outdated, let us know and we will correct it.

THE RIGHT TO REMOVE
You can ask ILC International to delete your personal data. Relevant legal grounds must be applied to fulfill the request. We may not be able to delete information about you that we are required to keep by law, or we have other legitimate reasons not store. ILC International will have one month to respond to your request. If we refuse to delete any information, we will provide justification as to the reasons of making this decision and the legal grounds for it.

THE RIGHT TO RESTRICT PROCESSING
In some cases, you may ask ILC International to not process your personal data, including the deletion of it, in order to protect your legal claims.

RIGHT TO OBJECT
In some cases, we process personal data because of business interests. You have the right to object to this processing, including when it represents profiling. We will stop processing data when we are sure that 1/ our business interests are not at a major disadvantantage in a particular situation, and 2/ we comply we the GDPR laws.

We remind you that at any time you can express your desire not to be a recipient of advertising content. In this case, we will immediately stop processing your data for the purpose of company communication.

THE RIGHT TO MOBILITY
You can ask ILC International to put your data in anelectronic file and transmit it to you or a third party. The data that you mayrequest from us may only be such that are provided to us in connection with acontractual relationship or with your consent and is processed in an automated(electronic) manner.

IV. HOW CAN YOU EXERCISEYOUR RIGHTS:
You can exercise each of the above rights in person orthrough a person explicitly authorized by you, as well as in electronic form inaccordance with the law on electronic document and electronic certificationservices:* by e-mail: connect@ilc.one or by letter to: ILC International LTD, EIK: 205545939,
address: Sofia, Lozenets, str. 1, Persenk, entr. A, fl. 3, The Republic Of Bulgaria.

V. CONTENT OF YOUR REQUEST:
Please keep in mind that in order to exercise any of your rights, your request(s) must contain minimal personal data (including: names and other identifying information, a description of your request, preferred method of communication, correspondence address, signature, and date).

ILC International may contact you for more information if your identity needs to be verified or your request clarified.

VI. COMPLAINT TO THE SUPERVISORY AUTHORITY:
If you are not satisfied with the actions of ILC International in relation to your personal data, we would like you to first inform us and allow the company to understand what the specific issue is in order to resolve it. We will carefully consider your request and answer all your questions.

If you believe you have not received adequate assistance from ILC International or that there is a violation of your rights, You have the right to file a complaint with the supervisory authority. This body in the Republic of Bulgaria is the 'Commission for the protection of personal data'.

VII. WHO CAN WE SHARE YOUR PERSONAL DATA WITH?
We believe that your personal information is confidentialand value its confidentiality. Therefore, we pay great attention to processing, which is the disclosure or provision of your personal data to third parties. Whenever we disclose your personal data, it is necessary to fulfill legal obligations only.

VIII. HOW LONG WILL YOUR PERSONAL DATA BE STORED?
The retention period of your personal data depends on the relationship you have with ILC International. When you apply for a free consultation but are not approved or you decide to opt out, your personal data will be stored for a limited time (1 year).

If you are a client and use the products and services of ILC International, we have a legal obligation to store your personal data not only for the duration of our contractual relationship, but also for 5 years after its termination. In some cases, this period may be extended to 7 years at the request of the competent state authority.

IX. CHANGES AND UPDATES TO THE PRIVACY POLICY
We will update this Privacy Policy in line with any changes to our services or the legal frame within which ILC International operated. As a client, you will be informed about how we process your personal data and if changes to the process occur.

This Notice on personal data processing was last updated on 28.07.2021.

This document is a privacy notice within the meaning of art.13 and art. 14 of regulation (EU) 2016/679 of the European Parliament and ofthe Council of 27 April 2016 on the protection of individuals in relation tothe processing of personal data and the free movement of such data and repealing Directive 95/46 / EC (General data protection regulation).

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