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English Български
English Български

Privacy policy

PRIVACY POLICY

 

 

Data protection is of a particularly high priority for SoFun OOD, a company duly registered at the Commercial register of the Registry Agency in the Republic of Bulgaria, with UIC 205127929, having its seat and management address in Bulgaria, Sofia, Zapaden park, block 52, entr. A, fl. 1, app. 1 and by means of this Privacy Policy, we would like to inform the general public of the nature, scope and purpose of the personal data we collect, use and process via the website: https://sofun.bg/ (“Website”) and of the rights data subjects are entitled regarding the protection of their personal data.

 

Furthermore, by means of this Privacy Policy, we assure that the processing of personal data will always be in line with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”/”GDPR”/”Regulation”) and the Personal Data Protection Act.

 

 

  1. Definitions

 

In this Privacy Policy, we use, inter alia, the following terms:

 

  1. “Personal data” is any information relating to an identified or identifiable natural person;

 

  1. “Data subject” is any identified or identifiable natural person;

 

  1. “Processing” is any operation or set of operations which is performed on Personal data or on sets of Personal data;

 

  1. “Controller” is the legal person SoFun OOD, which alone determines the purposes and means of the processing of Personal data;

 

  1. “Joint controllers” are the legal person SoFun OOD, which jointly with other controllers determine the purposes and means of the processing of Personal data;

 

  1. “Processor” is a natural or legal person, public authority, agency or other body which processes Personal data on behalf of a controller.

 

 

  1. Identity and contact details of the Controller

 

SoFun OOD, UIC 205127929

Bulgaria, Sofia, Zapaden park, block 52, entr. A, fl. 1, app. 1

Manager - Miroslava Toshkova Bayaslieva

Email address: info@sofun.bg

Phone: +359 888 57 25 94

 

 

III. Registration of an account

 

 

The registration of an account on the Website is voluntary. Users can view the Platform as well as make reservations of goods/services without a registered account.

 

Users can register their account on the Website and track the status and history of their reservations, both by providing their name and email address, as well as by signing in with Facebook. If the user makes their registration via Facebook, we will only gain access to the name and email of the user.

 

After the registration is completed a confirmation e-mail is sent to the user in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address is authorized to make a registration.

 

The data provided by users when registering an account are collected and processed by the Controller - SoFun OOD.

 

The Personal data are collected and processed on the grounds of article 6(1) lit. b GDPR, and namely processing is necessary for the performance of a contract to which the Data subject is party, i.e. the registration of an account or in order to take steps at the request of the Data subject prior to entering into a contract.

 

In the event that the Data subject does not provide the data required to register an account, the latter will not receive the requested service, and namely, will not be able to register his/her account on the Website.

 

 

  1. Reservation of goods/services

 

In case the user has a registered account, when making a reservation of goods/services, the data provided for in the account (name and email) will be automatically entered for the respective reservation. The user can change the latter. For certain reservations, the user will also have to provide additional data, such as a phone number.

 

When making a reservation of goods/services without an account, the user will have to provide a name, email and telephone number for each separate reservation.

 

The data provided for with each reservation, whether with or without an account, is processed by the Joint controllers – SoFun OOD and the relevant third party whose goods/services the user reserves (“Merchant”).

 

Upon completion of the reservation, the Merchant sends the user a confirmation email for the successful reservation or for the refusal of the reservation. The Merchant bears the sole responsibility for the email and its content.

 

The Joint controllers collect and process the data in order to perform the reserved services, send a correspondence regarding the reservation made, establish a contact by phone or email with the Data subject in connection with the reservation made.

 

 

The Joint controllers collect and process the above data on the grounds of article 6(1) lit. b GDPR, and namely processing is necessary for the performance of a contract to which the Data subject is party, i.e. the reservation of goods/services, or in order to take steps at the request of the Data subject prior to entering into a contract.

 

In the event that the Data subject does not provide the data required to make a reservation, the latter will not be able to complete the reservation and will not be able to receive the requested service.

 

 

  1. Prepayment and bank accounts

 

SoFun OOD does not provide its bank accounts and does not require any payments from users on the Website.

 

If a Merchant requires users to pay a prepayment to reserve his goods/services via the Website, he shall provide his bank account and he only receives sums on user-made payments. Sofun OOD does not receive any part of the sums prepaid and is not responsible for them.

 

Sofun OOD does not collect or process bank accounts of users of the Website. The latter are collected and processed only by the relevant Merchant requiring prepayment, which bears full responsibility for protection of the collected data.

 

 

  1. Newsletter

 

Upon registration of an account or reservation of goods/services, users can subscribe to a newsletter for promotions and news by ticking the relevant box. The latter is considered to be a given consent within the meaning of Art. 6, para. 4 of the Electronic Commerce Act and Art. 261, para. 1 of the Electronic Communications Act.

 

The data are collected and processed by the Controller on the grounds of article 6(1) lit. a GDPR, namely that the Data subject has given consent to the processing of his or her Personal data for direct marketing purposes.

 

The Data subject may withdraw his/her consent at any time, either by clicking the \"unsubscribe\" button at the end of each email received, or by contacting the Controller at the email address: info@sofun.bg or by phone +359 888 57 25 94.

 

 

VII. Disclosure

 

Your Personal data may be disclosed by either of the Joint controllers to:

  1. persons, if provided for in a normative act, including state bodies, in respect of which there is a statutory requirement to provide certain categories of Personal data;
  2. Processors by virtue of a contract between controller and processor, and namely, persons providing accounting services, IT services, etc. processing Personaldata only at the direction of the controller, unless processing is required by current legislation; Processors provide sufficient guarantees for the application of appropriate technical and organizational measures in such a way that the processing proceeds in accordance with the requirements of the Regulation and protects the rights of the Data subjects.
  3. persons who, under the direct authority of the Controller, process Personal data, have taken confidentiality commitment and are aware of the Personal data legislation.

 

 

VIII. Period for which the Personal data will be stored

 

Personal data in user\'s registered account is stored as long as the user maintains his/her account on the Website active and does not delete the latter.

 

Personal data provided for the reservation of goods/services (without a registered account) is stored for a period of 5 years as of the date of the reservation.

 

 

  1. Rights of the Data subjects

 

Right of confirmation

The Data subject shall have the right to obtain from the Controller confirmation as to whether or not Personal data concerning him or her are being processed, and, where that is the case, access to the Personal data and the following information: the purposes of the processing; the categories of Personal data concerned; the recipients or categories of recipients to whom the Personal data have been or will be disclosed, in particular recipients in third countries or international organisations; the envisaged period for which the Personal data will be stored; the existence of the right to request from the Controller rectification or erasure of Personal data or restriction of processing of Personal data concerning the Data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the Personal data are not collected from the Data subject, any available information as to their source; the existence of automated decision-making, including profiling.

 

Right of access

The Controller shall provide a copy of the Personal data undergoing processing. Where the Data subject makes the request by electronic means, and unless otherwise requested by the Data subject, the information shall be provided in a commonly used electronic form.

 

Right to rectification

The Data subject shall have the right of direct rectification via the functionalities of the Website or to obtain from the Controller without undue delay the rectification of inaccurate Personal data concerning him or her. Taking into account the purposes of the processing, the Data subject shall have the right to have incomplete Personal data completed.

 

Right to erasure (Right to be forgotten)

The Data subject shall have the right to terminate his account and the Personal data concerning him or her or to obtain from the Controller the erasure of Personaldata concerning him or her without undue delay.

 

Right of restriction of processing

 

The Data subject shall have the right to obtain from the Controller restriction of processing where one of the following applies:

  1. the accuracy of the Personal data is contested by the Data subject, for a period enabling the Controller to verify the accuracy of the Personal data;
  2. the processing is unlawful and the Data subject opposes the erasure of the Personal data and requests the restriction of their use instead;
  3. the Controller no longer needs the Personal data for the purposes of the processing, but they are required by the Data subject for the establishment, exercise or defence of legal claims;
  4. the Data subject has objected to processing pending the verification whether the legitimate grounds of the Controller override those of the Data subject.

 

Where processing has been restricted, such Personal data shall, with the exception of storage, only be processed with the Data subject\'s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

 

Right to data portability

The Data subject shall have the right to receive the Personal data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Controller to which the Personal data have been provided.

 

In exercising his or her right to data portability, the Data subject shall have the right to have the Personal data transmitted directly from one controller to another, where technically feasible.

 

Right to object

Where Personal data are processed for direct marketing purposes, the Data subject shall have the right to object at any time to processing of Personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

 

Where the Data subject objects to processing for direct marketing purposes, the Personal data shall no longer be processed for such purposes.

 

Automated individual decision-making, including profiling

The Controller does not perform automated decision-making and profiling.

 

Right to withdraw data protection consent

The Data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the Data subject shall be informed thereof.

 

Exercise of a right

If a Data subject wishes to exercise the hereinabove rights, he or she may, at any time, contact the Controller or directly make the necessary changes from the functionalities of the Website.

 

Where the Controller has reasonable doubts concerning the identity of the natural person making the request, the Controller may request the provision of additional information necessary to confirm the identity of the Data subject.

 

 

 

The Controller shall provide information on action taken on a request to the Data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

 

The Controller shall inform the Data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.

 

If the Controller does not take action on the request of the Data subject, the Controller shall inform the Data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

 

Right to a complaint

Every Data subject has the right to lodge a complaint with the competent supervisory authority and before the competent courts of the Member States of his or her habitual residence, place of work or place of the alleged infringement if the Data subject considers that the processing of Personal data relating to him or her is in breach of the provisions of the Regulation.

 

The supervisory authority in the Republic of Bulgaria is the Commission for Personal Data Protection, address: Sofia 1592, 3 Prof. Tzvetan Lazarov Str., phone: 02 / 91-53-518, email: kzld@cpdp.bg, website: www.cpdp.bg.

 

Right to information in case of Personal data breach

In the case of a Personal data breach, the Controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the Personal data breach to the competent supervisory authority, unless the Personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.

 

The Controller shall document any Personal data breaches, comprising the facts relating to the Personal data breach, its effects and the remedial action taken.

 

When the Personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Controller shall communicate the Personal data breach to the Data subject without undue delay.

 

 

  1. Security of the Рersonal data

 

The Controller has implemented appropriate technical and organisational measures to ensure that processing is carried out in accordance with the Regulation and ensure the protection of the Data subjects\' rights. These measures are reviewed periodically and, where necessary, updated.

 

The Controller has implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

  1. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  2. the ability to restore the availability and access to Personal data in a timely manner in the event of a physical or technical incident;
  3. a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

 

The Controller has taken steps to ensure that any natural person acting under the authority of the controller who has access to Personal data does not process them except on instructions from the Controller, unless he or she is required to do so by Union or Member State law.

 

 

If you believe that any information about you is false or inaccurate, please inform us as soon as possible.

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