Fulbright Bulgaria Privacy Statement
Our commitment to your privacy
We, the Bulgarian-American Commission for Educational Exchange (the “Commission”) are committed to protecting and respecting your privacy. Please be aware that we will collect and process personal information in connection with your application to the Program. The Program is funded by the Bulgarian Government through the Ministry of Education and the U.S. Congress through the Bureau of Educational and Cultural Affairs (“ECA“) of the U.S. Department of State.
Please read the following statement carefully as it details the way in which we process your personal data:
Who controls and processes your data
As a sovereign state, the United States is not subject to the EU’s General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”), but the Bulgarian-American Fulbright Commission for Educational Exchange is a separate legal entity from the United States Government and will comply with applicable data protection regulations, including GDPR.
The address of the Commission appears below.
Information we collect from you
We may collect and process personal data which you provide to us in connection with your application and the subsequent award selection process. This may include:
- Identifying contact information such as your contact details, age, gender, marital status, user-name, government issued identification (passport/ID) and picture;
- Academic and professional information such as your academic history, job titles, salary, work history, school attended, employee files, employment history, evaluations, professional references, interviews and certifications;
- Family information such as your family structure, siblings, details of dependents, marriages, divorces and relationships;
- Information about your personal history such as your travel history and other events in your life; and
- Information about your preferences such as your opinions, intentions and interests.
In addition, we may collect, hold and use sensitive personal data that you may choose voluntarily to provide as part of the Award Selection Process. This sensitive personal data could include the following (the “Volunteered Sensitive Personal Data“):
- Information concerning your health;
- Information about your political views;
- Information about your sexual orientation;
- Data revealing racial or ethnic origin;
- Political, religious or philosophical beliefs;
Purposes for which and the basis upon which we will process this personal data
We will process this personal data for the following purposes:
- where you provide us with explicit consent through a separate consent form, to process Volunteered Sensitive Personal Data for the purpose of assessing your Application;
- as necessary to enter into a possible award contract with you because we require it to assess your Application. Failure to provide the necessary personal data will result in us being unable to assess your Application;
- as required by us to pursue our legitimate interests or the legitimate interests of others, in particular:
- when assessing your Application;
- when investigating any complaints received from you or from others, about us, our service providers, or the application process;
- in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
provided that the above legitimate interests are not overridden by the interests or fundamental rights or freedoms of the individuals whose personal data we are processing.
Disclosure of personal data
We may share the personal data with third parties, who will process the personal data during the application and selection stages. Such third parties include:
- the Institute of International of Education (“IIE“), the agency contracted by ECA to administer the Fulbright Program for which you are submitting an Application);
- the Embark Corporation, the application platform provider managed by IIE;
- Reviewers and members of Fulbright Selection Committees as appointed by the Commission;
We will ensure that these service providers follow our instructions when processing the personal data.
Retention of personal data
The personal data on the Application will be held on the application platform and by the Commission for two years for unsuccessful applicants and for five years for successful applicants for the Fulbright award.
Where we process personal data with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to process your data indefinitely so that we can respect your request in future.
Your rights under the EU General Data Protection Regulation
You have rights under the GDPR including:
- the right to access your personal data;
- the right to have your personal data rectified if it is inaccurate or incomplete;
- the right to have your personal data deleted or removed if there is no reason for its continued storage and processing;
- the right to object to your personal data being processed and to restrict the processing of your personal data in certain circumstances;
- the right to request the transfer of your personal data to another party; and
- where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent. Please note that the withdrawal of your consent will not affect the lawfulness of any processing of personal data based on your consent before its withdrawal.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
You may address your requests to Angela Rodel. You can, in principle, exercise your rights free of charge, subject to statutory exceptions.
Is Personal Data used for direct marketing communications?
Fulbright may, from time to time, contact you by email with information about Fulbright activities, newsletters and alumni opportunities. Fulbright will never share your contact information with third parties. If you no longer want to receive emails from Fulbright, please let us know by sending an email to us at firstname.lastname@example.org.
Changes to this Statement
We reserve the right to change this Statement and any other relevant policies or procedures at any time without notice to you. Any changes we may make to this Statement in the future will be posted to the Commission website (fulbright.bg) and you are advised to regularly check and review the Statement to ensure you understand how we may be processing your personal data. Any changes that we may make to this Statement will be effective from the date on which those changes have been posted on this page. Where appropriate, we may also notify you of any changes made by e-mail.
If you have any questions concerning this Statement or the policies or procedures referred to above, please contact our executive director at:
Angela Rodel, Executive Director
BULGARIAN-AMERICAN COMMISSION FOR EDUCATIONAL EXCHANGE
12 Vitosha Blvd, 5th Floor, 1000 Sofia, Bulgaria
+359 2 981 8567
Where you are dissatisfied with any aspect of our handling of your personal data you have a right to lodge a complaint with:
Bulgarian Commission for Personal Data Protection
2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
We hope that we can satisfy queries you may have about the way we process your data. If you have any queries or concerns about the way we process your personal data, please get in touch by email or telephone.