DECLARATION – NOTICE ON CONFIDENTIAL PROCESSING OF PERSONAL DATA

Through the website of DINEV GROUP JSC – https://www.dinevigroup.bg/, hereinafter referred to as DINEV GROUP, or “we”, through our partners, we provide various services such as sale and rental of real estate, hotel services, car rental, sale and rental of yachts, accommodation in holiday properties, the provision of advertising space and other services listed on our site.

When you use the services provided by DINEVI GROUP , you entrust us with your personal information.

This confidentiality notice aims to help you understand what data we collect, why we collect them, and what we do with them. This is important and we hope you will take time to read the information carefully.

What is personal data?

According to the General Data Protection Regulation (GDPR), personal data is defined as: “Any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Other basic definitions:

“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

“recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

“third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

“consent of the data subject” means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Why DINEV GROUP collect and store personal data?

To provide you with any of our services through our partners, such as real estate sales and rentals, hotel services, rental cars, yacht sales and rentals, vacation rentals, advertising space, online reservations and payments – bank transfer via credit and / or debit card, to register you to receive the relevant service, so that we can provide you with the information required for identification before entering into a contract with you.

We guarantee that the information we collect and use is indispensable for any of the above purposes and is not intended to enter your private space or the sanctity of your private life.

For the purposes of communication with advertising and marketing intentions, Venid EOOD, Venid Jet AD, Venid Pamporovo EOOD will ask you for your explicit consent to receive your personal data.

What categories of personal data we collect and process?

The categories of personal data that we process are the following: three names, phone number, email address, date and place of birth, personal identification number, permanent and current address, identity card details – number and date of issue, bank account number, income, IP address.

We receive your personal data, as our customers, online or offline, on the basis of your consent granted on the basis of a contract signed between us or by law.

What types of cookies does the website of DINEV GROUP, use?

We use our own and third-party’s cookies to manage the website’s content, to produce personalized ads, to measure the results, and to analyze the traffic. Learn more about our Cookies Policy.

The personal data that we collect will only be used for one or several of the following purposes:

• To provide any requested by you information;
• Correspondence prior to conclusion of a contract;
• Identification in preparing the documents required for conclusion of a contract;
• Identification in preparing the documents required for conclusion of a tenancy or sale contract;
• Marketing and / or advertising information;
• Producing personalized ads, remarketing and results measurement;

If we need to use your personal data for a new purpose, not covered by this privacy notice, we will send you a new notice, and when and where necessary, we will require your prior consent for the new processing.

Grounds for collecting and storing personal data:

The grounds that entitle us to process your data is one or more of the following:

• your consent;
• with the purpose of fulfilling a contract signed with you or our intention to enter into such kind of a contract;
• when such processing is necessary to comply with our legal obligation;
• to protect your interests or another person’s interests, and to protect our legitimate interest.

Children’s personal data:

We do not provide our services to persons under the age of 18. We do not collect personal data from children under the age of 16. If we learn that we process personal information of a child under the age of 16, we will take steps to delete the information as soon as possible. If parents and/or legal representatives of children find that children, under their guardianship, have given their data to Dinevi Group, please, contact us at the contact details specified in this notice. We will delete the information as soon as possible.

Disclosure of your personal data to third parties:

The following organizations may obtain from us, only if necessary, your personal data:

• The bank institution we work with regarding your deal;
• The lawyer with whom we work regarding your deal;
• The Notary Public with whom we work regarding your deal;
• The Translator with whom we work regarding your deal;
• The insurance broker with whom we work regarding your deal;
• The accounting office we work with;
• Our partner offices;
• Google, FaceBook and other advertising networks and platforms.

When any of the companies – DINEV GROUP,  shares information about you with third parties – subcontractors of DINEV GROUP, then we conclude contracts with these third parties-subcontractors and take measures to ensure that they provide a level of data protection in accordance with the agreed standard and in accordance with the requirements of Regulation (EC) 2016/679 (“GDPR”) and the applicable legislation. Your data are also considered confidential by our partners.

It may become necessary – by law, in case of court proceedings, litigation and/or upon request of any public and governmental authorities in or outside your country of residence – any of the companies DINEV GROUP, to disclose your personal data. It is possible also to disclose information about you, if we find that such disclosure is necessary or appropriate for the purposes of national security, law enforcement or other matters of public concern.

Transmission of personal data to a non-EU country or to an international organization

DINEV GROUP, do not intend to transmit your personal data to third parties without having informed you in advance and received your consent to do that.

Data storage period:

We process and store personal data for a period necessary to fulfil the purposes set out in this Privacy Policy, unless we are required by law to retain it for a longer period. Depending on the type of data and the purpose for which it was collected, a storage period is set for expiry of which information is deleted.

Your rights as a data subject are as follows:

At any time while we store or process your personal data, you, as a data subject, have the following rights:

• You have the right to request a copy of your personal data from DINEV GROUP and the right of access at any time to your personal data;
• You have the right to ask DINEV GROUP to correct without undue delay your inaccurate personal data as well as the data that are currently not valid;
• You may request DINEV GROUP to delete your personal data without undue delay in any of the following cases:
  • the personal data are no longer needed for the purposes for which they were collected;
  • when you withdraw your consent, if the grounds for processing and storing of personal data is a concent;
  • when you have objected to the processing;
  • when the processing is unlawful;
  • when the personal data must be deleted in order to comply with a legal obligation under EU law or the legislation of a Member State that applies to us as a data controller;

• We have the right to refuse to delete your personal data due to the following reasons:
  • when exercising the right of freedom of expression and the right to information;
  • to comply with a legal obligation on our part or to carry out a task of public interest;
  • when exercising official powers, that you have assigned to us for a particular conclusion of a property sale deal;
  • for reasons of public interest in the field of public health;
  • for the purposes of archiving in the public interest, for statistical purposes, as far as there exists possibility the deletion to make impossible or seriously to obstruct the achievement of the purposes of such processing;
  • or for the establishment, exercise or protection of legal claims.

• You have the right to request DINEV GROUP EOOD to restrict the processing of your personal data, in which case the data will only be stored but not processed. Our refusal to restrict will be explicit only in writing, and we are obliged to give legal reasons for such refusal;
• You have the right to withdraw your consent for processing of your personal data at any time with a separate request addressed to DINEV GROUP, in case the grounds for processing and storing of your personal data is a concent;
• You have the right to object at any time against the processing of your personal data when there are legitimate reasons for doing so;
• You have the right to transfer your data in a structured, widely used and machine readable format;
• You have the right to lodge a complaint with the Personal Data Protection Commission, if you believe that your data protection rights have been violated.

Policy for voluntary settlement of issues in controversy:

It is our policy to voluntarily settle all controversial issues arising in relation to the processing of your personal data and we will therefore welcome you if you first contact our Data Protection Officer before submitting a direct complaint to the Supervisory Authority.

How will we store and protect your personal data that we collect?

Dinevi Group will process (collect, store and use) the information you provide in a manner consistent with the requirements of the General Data Protection Regulation ARRD and the Personal Data Protection Act in force in the country. We will strive to keep the information accurate and valid.

We will not store your data for a period longer than is reasonably necessary to meet the specific purposes for which such data were collected and of which you have been informed herein.

Some of the storage periods depend on legal obligations to keep documents and information within certain minimum periods, such as the Accounting Act or the Measures against Money Laundering Act. We will take all foreseeable technical and organizational measures to protect your data from unauthorized access, such as encryption, anonymisation, masking and erasure after expiration of the storage period.

Update

We have the right to periodically update this Declaration, with which update you will be acquainted with. Upon change in this declaration, a message will be posted on our website as well as the very updated Declaration – confidentiality.