Notice for Privacy and Personal Data Protection
by Addventure Services EOOD
What is this “Notice”?
Addventure Services EOOD (Addventure) takes the responsibility for protection of personal data which it collects in connection with the performance of its economic activity seriously. This Notice clarifies our approach to collecting, processing, storing, distributing and deleting personal data with which the company operates. This information is targeted at individuals – our employees, clients, agents, subcontractors or partners.
In this “Notice”, the words “you” or “your” will refer to you as a physical person – our employee, customer, agent, counterparty or partner.
What is “personal data”?
“Personal data” is data about you as an individual (“a data subject”) which can uniquely identify you.
Applicable legislation
Our approach in handling your personal data is consistent with the requirements and principles set forth in the Personal Data Protection Act of the Republic of Bulgaria and Regulation 679/2016 of the European Parliament and the Council.
Who are we?
ADDVENTURE SERVICES EOOD is a company registered in the Commercial Register at the Registry Agency under UIC 200132833, with registered office and management address: Bulgaria, Sofia 1618, j.k. Buckston, bl.20A, web: www.addventure.bg. We operate with personal data in the capacity of:
- “Personal data processor” under contracts with partners who are personal data administrators
- “Administrator” of personal data in connection with the products and services we offer
within the meaning of the Personal Data Protection Act and in accordance with the principles outlined in the General Data Protection Regulation 2016/679.
Our Data Protection Officer is Stanislav Tanushev with e-mail: tanushev@addventure.bg.
Principles which we observe
When working with personal data, Addventure complies with the following principles:
- Applicability: Addventure does NOT collect and process personal data which is not directly applicable in its activity;
- Liability: Legitimacy, conscientiousness and transparency (relative to the individual) of the processing;
- Specificity: The data being processed are specific and appropriate to Addventure’s activity;
- Accuracy: The personal data must be accurate and, if possible, current;
- Security: Maximum security of data processing;
- Limited storage: Personal data must be stored only for the time it is needed.
What personal data we process:
When you work with us, we may ask you for different personal information, such as your name, address, telephone number, date of birth, PIN, email address, marital status, etc. as well as information about your business, sales, income, etc.
Addventure also collects and processes information collected through various communication technologies such as IP addresses, online identifiers, usernames, passwords, location, device-specific information, cookies which can uniquely identify the browser used, etc.
Last but not least, we collect personal information about your behavior as a counterpart, such as which products and / or services you use, what special requirements you have, etc.
In all cases where we have access to, and process data about you, we comply with the principles outlined in this document and with the requirements of the applicable data protection legislation.
Data sources for personal data
We collect and / or receive the above data in the following ways:
- Information provided by you (as our employee, client or partner).
- Information provided by third parties (eg. public authorities / institutions, financial institutions, our partners, personal data controllers, related persons, persons performing public functions, etc.).
- Information we receive when you use our services.
- Information available in public registers and the Internet.
- “Cookies” and similar technologies.
- Other sources.
Why do we collect personal data?
We collect and use your personal data for the following purposes:
- To allow you to use our online products or services;
- To give us the opportunity to enter into business relations;
- To enable us to fulfill our contractual obligations to you;
- Allow us to process your requests/applications and provide you or the company you represent with our products and / or services;
- Allow us to contact you in connection with our business relationship;
- Allow us to send you recommendations, tips, news and promotions;
- Implement any legal requirements or obligations;
- For storing, archiving and searching documents related to our business relationship.
Marketing messages
For direct marketing purposes, we use and process your data so that we can inform you directly about our latest products, services, news and promotions and offer:
- Better conditions than previously used by you.
- Products which you have not used, but we think they would be of interest.
- Special offers and promotions prepared by our specialists.
- Products and services offered by our partners, which Addventure distributes as an intermediary (eg leasing products, insurance, cars, promotions, etc.).
If you do not wish to receive marketing communications from us, you have the full right to opt out of them in one of the following ways:
- By written instructions, sent to e-mail tanushev@addventure.bg ,
- By a using the deactivation link at the end of each marketing message to you.
Upon receipt of such communication from you, Addventure will discontinue processing your data for direct marketing purposes.
Grounds for processing your personal data
We use your personal data when permitted by law and when:
- We must use your personal information to execute your order or contract with you, to which we are a party (for example, your Lease Application);
- We need to use your personal information to comply with a regulatory or legal obligation (for example, to issue an invoice for the service you have used);
- You have explicitly given us your consent to use your personal information when we have asked you (for example, to send you promotional or other direct marketing messages);
- The use of your personal data is in our legitimate interest (for example, to conduct a check under the Money Laundering Act).
If you do not provide us with the personal data we require from you or withdraw our right to use them, Addventure may not be able to perform the functions you want or you may not be able to use our products and / or services.
Who do we share your personal information with?
We do not provide your personal data to countries outside the European Union.
To fulfill our duties, Addventure may provide your personal data to the following bodies (depending on the nature of our relationship):
- Our subcontractors who help us with the processing of information (for example our IT service providers);
- Service providers we use (for example, “Bulgarian Post” or courier companies);
- Our leasing companiesA company whose main activity is... More – partners (when we are working on your Lease Application);
- Our insurers and insurance brokers (when working for the insurance coverage of your asset);
- State and regulatory authorities and agencies (eg. NRA, SANS, CPDP, etc.).
What are your rights with respect to your personal data processed by us?
The legal basis, governing the protection of personal data gives you the following rights as regards your personal data:
- Access: You can request access to a copy of your personal information by e-mail to tanushev@addventure.bg ;
- Withdrawal of consent: When the processing of your personal information is based on your consent (for example, for receiving marketing materials and promotions), you may withdraw your consent at any time;
- Adjustments: You may ask us to correct any inaccuracies in the information we process about you;
- Deletion: You may request us to delete personal information which we process about you, if there is no reason to do so;
- Objection: You may object to our processing of your personal information;
- Complaint: In case you are not satisfied with our processing of your personal data or with our response to your requests, related to it, you may file a complaint with the Personal Data Protection Commission at: Bulgaria, Sofia 1592, Blvd. Prof. Tzvetan Lazarov 2, tel. +359 2 / 91-53-518, e-mail: kzld@cpdp.bg .
Term for storing personal data
Addventure retains personal data for a period not exceeding 10 years from the year following the year of completion of the relationship in respect of which the personal data was collected and as long as there is no other reason for processing the data.
Changes to this information
We may update the text of this document, from time to time, in order to provide the most up-to-date and accurate information about the processing of personal data in accordance with our Policy and in compliance with current legislation related to personal data. Any change will be announced on Addventure’s website and / or using the company’s direct marketing system.
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