Personal Data Processing Policy and
Declaration of Transparency
The team of Euro Property BG Ltd. (hereafter referred to as “Europroperty”) is strongly committed to the protection of personal data. This Personal Data Collection Policy and the Declaration of Transparency describe why and how we collect and use personal data for the purposes of our activity when we collect and use it.
We handle the security of all data with great responsibility. We implement well established Internal Rules for Information Security and Protection of Personal Data. We regularly review the appropriateness of the measures we apply to keep the data protected.
Legal basis for the processing of personal data
We will process your personal data on the basis of legal requirements and in accordance with the Internal Rules on Information Security and Protection of Personal Data.
Please read this Personal Data Collection Policy and Declaration of Transparency carefully before using the Website or submitting your personal information, whether electronically, on the Website or on paper, as with the provision of your personal data you agree to the Policy’s terms.
If you do not wand us to process your personal data in the manner described in this Personal Data Collection Policy and Declaration of Transparency, please do not provide it to us.
The provision of personal data on your behalf is voluntary in order to use certain services provided by us and the use of the Website and/or access to it. Please note that in some cases we will not be able to provide you with the service or goods you have requested if you do not provide us with the necessary information.
Please also note that in certain cases your consent to the processing of personal data may not be necessary if Europroperty has another legal basis, e.g. compliance with statutory obligations.
Who processes and is responsible for your personal data?
Euro Property BG Ltd. is an administrator of personal data within the meaning of the Personal Data Protection Act (PDPA). You can contact us at any of the following locations:
Registered address: 1616 Sofia, 28 Daskal Stoyan Popandreev Str.,
Categories of personal data processed by Europroperty
Europroperty may process publicly available personal data and/or personal data provided by you. The main types of personal data processed are:
- Personal identification information (including name, National ID No., ID document No., place of residence, citizenship, language of communication, etc.);
- Information about the sphere of activity (including education, educational institution, workplace, work position, etc.);
- Contact details (including postal and e-mail addresses, telephone and fax numbers, etc.);
- Financial information (bank account, etc.);
- Information about a representative (legal representative or proxy of one) of our customer that is a legal entity;
- Data from the communication between us and you, your habits, preferences and satisfaction with our services (activity when using the services, complaints, requests, etc.);
- Information about visits to the Website and the use of the Website, including operations and history of using the Website;
- Data obtained from the performance of obligations deriving from regulatory deeds (i.e. data arising from inquiries, regulations, investigative bodies, notaries public, tax offices, courts, enforcement agents);
- Data obtained from the performance of contractual obligations (including name, address, telephone and/or e-mail address, etc.).
- Data for access to a portal for online orders (e-mail, delivery address).
Europroperty may process data prepared and generated by Europroperty in the process of providing the services:
- data about the terminal electronic communication device used, the type of the device, the operating system used, the IP address, the location;
- data about your preferred goods and services
- video recording when visiting the Europroperty offices/sites;
- data obtained from comments on the Website.
In order to ensure the proper performance of the services and obligations arising from contracts with customers, Europroperty has the right to process any information that is available in public registers (including a public database and data disclosed on the Internet), as well as information about customers received from third parties with regard to law enforcement.
Europroperty has the right and is obliged to verify the authenticity of the personal data stored in the database and requires you to verify the data and, if necessary, correct or validate the authenticity of your data.
Different types of personal data can be processed on their own or in combination with one another.
Purposes and legal grounds for processing of personal data
Processing of personal data that is necessary for the conclusion or performance of contracts with us or in connection with the preparation for concluding contracts with us.
Europroperty processes your data for the following purposes:
- Identifying a customer upon: concluding a new or changing an existing contract with us; explanations of the services used; performance of a concluded contract.
- Making proposals for signing contracts, sending pre-contractual information and a draft contract;
- Data obtained from you in fulfilling obligations arising from contracts concluded with you or a company represented by you, exercising of rights and ensuring the performance of contracts by our customers;
- Service and response to customer complaints / inquiries / petitions / claims;
- Payment of obligations, rescheduling of amounts due.
In fulfillment of its legal obligations, Digital Children processes your data for the following purposes:
- Issuing of invoices;
- To carry out tax and social security control by the respective competent authorities;
- Obligations stipulated in the Accountancy Act and the Tax and Social Security Procedure Code and other related regulatory deeds in relation to the keeping of proper and lawful accounting
Europroperty processes the relevant data provided with the explicit written consent of the customer for their processing for the following purposes:
- For direct marketing of products and services; an electronic newsletter;
- Data provided by you when participating in raffles, polls, games, etc.
Processing is necessary for the purposes of the legitimate interests of Europroperty.
- For scientific purposes, security and protection of the interests of visitors and employees, Europroperty can use video surveillance equipment to make video recording when visiting am Europroperty’s office
- In connection with Europroperty’s research and development and statistical purposes
- Evaluation and establishment of user satisfaction, as well as the effectiveness of the advertising we offer you and others, and meeting your expectations by presenting adequate advertising;
- Analysis of the data about the purchase history, preferences and behavior of the customers;
- In order to protect the Website from obscene and indecent comments and unfair competition, when commenting on the Website we require identification by name and e-mail.
How and when we share personal data
We will share personal data with others only when we have a legitimate right to do so. When we share personal data with others, this happens on the basis of contractual agreements and security mechanisms in order to protect the data and comply with our standards of protection of personal data, as well as the requirements of confidentiality and security.
Personal data stored by us may be transferred to:
- Third-party providers that provide us with applications / functionality, IT services or data processing services.
- We use third parties to assist us to provide our services, as well as help us with providing and managing our internal IT systems. For example, information technology providers, cloud service providers, identity management, website hosting and management, data analysis, data backup, security and storage services. Servers that support this cloud infrastructure are located in secure data centers around the world and personal data can be stored in any of them;
- Third-party providers that otherwise assist us in providing goods, services or information;
- Auditors and other professional consultants;
- Law enforcement authorities, other governmental and regulatory agencies or other third parties as required by and in accordance with the applicable laws;
- Sometimes we may receive claims from third parties who have the right to request information about personal data, such as to verify whether we comply with the applicable laws and regulations so as to investigate a suspected offense in order to establish, exercise or protect legitimate rights. We will only fulfill requests for provision of personal data when it is permitted to do so in accordance with the applicable laws.
Rights of individuals and how to exercise them
Individuals have certain rights to their personal data. Data controllers are responsible for the implementation of these rights. When we decide how and why personal data is processed, we are the administrator of that data. Below we include additional information about the rights that individuals have and how they can exercise them.
Access to personal data
You have access to your personal data that we hold as an administrator. Those rights can be exercised by accessing the information you have provided in the Europroperty database.
Change of personal data
In order to update your personal data, you can send an e-mail to the administrator of the database that has been listed as administrator.
When practically possible and once we have been informed that some of our personal data we have processed is no longer correct as they were submitted at the date of the Annual Return, we will make changes (where appropriate) based on your updated information.
Right to restrict or oppose the processing of personal data
You may restrict or object to the processing of your personal data at any time on reasonable grounds relating to a particular situation, unless processing is required by law.
In that case, we will no longer process or restrict the processing of personal data, unless we can prove insurmountable legitimate reasons for the processing or the establishment, exercise or protection of legal claims.
Other rights of data subjects
This Personal Data Collection Policy and Declaration of Transparency is intended to provide information about what personal data we collect about you and how it is used. In addition to the right of access, alteration and restriction or opposition to processing mentioned above, individuals may also have other rights with respect to the personal data we process, such as the right to erasure / deletion and the right to data portability.
For www.edelweiss-3.com (“the Website”) to function according to the capabilities set by Europroperty’s team, as well as to personalize your visits, sometimes we store on your device small data files called cookies. This is a standard practice that is widely used in almost all websites around the world. This document explains how we do this.
What are cookies?
Cookies are small files saved by your browser on your device. They allow you to identify the user’s device and achieve the correct behavior of a web page according to his/her individual preferences. In this way, the functionality of the Website is improved. Cookies typically contain the name of the Website, the time for storage on the terminal device and a unique number. In certain cases, cookies also allow personally identification of the users.
Cookies are used to adapt the content of the Website to the user’s preferences and to optimize the use of the Website. They are also used to create anonymous statistics (on the user’s behavior on the Website) to improve the structure, design, appearance and content of the Website.
What types of cookies do we use?
Europroperty may also allow the use of third-party cookies, such as cookies associated with software products that record anonymous user statistics (Google Analytics, Facebook, etc.).
Alternatively, third-party cookies may be associated with “social” buttons or plug-ins that allow page sharing and interaction with social networks. In order for those tools to work, social networks (such as Facebook, Twitter, Instagram, etc.) can store cookies via the website to interact with the user’s anonymous profile on a network or add data to the information collected in such a way and for such purposes as set out in their respective policies and web pages.
We do not have access to or control over cookies that are used and provided by third parties. This Policy does not apply to the way a third party collects and treats such information. It is good to get familiar with the relevant third-party policies in order to be aware of their practices and behaviors.
Personal data collected by cookies can only be used to carry out specific functions on the Website that are linked to the user him/herself.
How to control cookies through the Website?
If you have already made your choice and want to change it, click the “Cookie Settings” button and change your choice.
How to control and/or delete cookies using your browser?
Most websites automatically accept cookies, but if you do not want to accept them, you can configure your browser to reject them.
Most web browsers allow cookies to be controlled through browser settings. Typically, you can find these settings in the “Options, Settings, Preferences” menu. You could delete all the cookies already stored on your computer, as well as to set up most browsers to block them completely.
However, if you do so, you may have to manually set up some parameters each time you visit a site, and some services and features may not work. Unfortunately, in most cases, there is no universal option to disable cookies without limiting the functionality they add to the relevant website. To find out more about cookies – including how to control them – you can visit Cookiepedia (the information is in English).
Keep in mind that blocking cookies will affect the way the website works and may cause malfunctions of the website.
We hope that you will never have to, but if you still need to file a complaint about the use of your personal data, please send an e-mail with your complaint to the administrator of the database to email@example.com. We will look into and answer all the complaints we receive.
You also have the right to file a complaint with the Commission for Personal Data Protection. For further information on your rights and filing complaints to the Commission for Personal Data Protection, please refer to its official website.