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PRIVACY POLICY

Contact information for Supervisory Authority
Commission for Personal Data Protection
Address: Sofia, P.O. Box 1592, Prof. Tsvetan Lazarov Blvd. No. 2
Website: www.cpdp.bg

It is advisable to take the time to familiarize yourself with this Privacy Policy, and to review it periodically as we may change it at some point.

  1. Scope
    The protection of your personal data is a high priority for “KLIMATI HOLIDAY” Ltd. This Privacy Policy discloses how “KLIMATI HOLIDAY” Ltd. collects, stores, processes, protects, uses and disseminates personal and other data collected about you in writing, orally, electronically or while you use the websites (together with any other and any future website, hereinafter referred to as the “Website”). Our personal data protection practices are in accordance with the current Bulgarian data protection legislation and 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.
  2. Key definitions
    For the purposes of this Privacy Policy, the following terms are used:
    Personal data is any information relating to an identified person or a natural person who can be identified, including but not limited to: (a) first name or initial and last name; (b) personal identification number; (c) permanent or current address; (d) telephone number; (e) e-mail address or online identifier associated with the person; (f) data regarding financial status, health status or data regarding professional experience; (g) behavioral or demographic characteristics when linked to personal identifiers; (h) voice data and video image; or (i) any other information relating to a person which is combined with any of the above.
    Other data, as defined by applicable law, which may be anonymized and/or aggregated information, as well as any other information that does not reveal the identity of the person or is not directly linked to them. Other data may include, but are not limited to: cookies, IP address and information obtained from the IP address, information contained in HTTP headers. Other data stored in internet protocols, browsers or various devices, operating systems and information used by “APPS” applications on your mobile device, screen resolution, behavioral data about your use of the sites and preferred languages.
    Processing of personal and other data means any operation or set of operations performed on personal or other data by automated or other means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.
    Sensitive personal data are a type of personal data which may include, but are not limited to, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
    Suppliers of goods and services, third parties which we use under contractual relations to fulfill our legal obligations and conduct our commercial activity and to provide you with many of our services, functions and aspects of the Website.
  3. What personal and other data we collect
    Our privacy policies depend on the type of relationship you have with “KLIMATI HOLIDAY” Ltd. and on legal requirements. We strive to collect personal and other data only to the extent necessary to provide you with products, services or information you have requested or to recruit the necessary staff for the normal functioning of the Company. We may use the information to improve the functionality of using our Website, in accordance with this Privacy Policy. Below are the grounds and some of the ways we collect and use information.
    Your personal data may also be collected in connection with Customer programs and games organized by “KLIMATI HOLIDAY” Ltd. Each Customer program and Game has individual terms, with a detailed description of the participation rules, prize pools, the necessary personal data that will be collected, the collection methods, retention periods and processing purposes.
    When organizing such Customer programs and games, “KLIMATI HOLIDAY” Ltd. also complies with the general rules for personal data protection determined by the specific social platform on which the Game is distributed. Usually, but not only – Facebook, Twitter, Instagram.

3.1. Users
“KLIMATI HOLIDAY” Ltd. collects user data in various ways. In all cases, we collect only the personal data that you have voluntarily provided to us and we do not collect any other data that has not been provided to us without your voluntary consent.

3.1.1. Personal data you have provided voluntarily
You may choose to communicate with us and provide personal data, such as your:
• names, postal and e-mail address, telephone and/or mobile number, city, postal code, age, bank account and other information.

3.1.2. For what purpose we use your personal data
“KLIMATI HOLIDAY” Ltd. uses the above-described data when provided by Users, in cases of:

  1. performance of a contract concluded with a client, including delivery of goods and services;
  2. submission by clients of opinions, complaints, suggestions, objections, etc.;
  3. customer satisfaction survey;
  4. providing a response;
  5. connecting to the Wi-Fi network provided by the restaurants and accommodation facilities of “KLIMATI HOLIDAY” Ltd.;
  6. contacting us by phone, e-mail or mail with a question, recommendation or complaint;
  7. responding to your inquiries and complaints related to the quality of the offered goods;
  8. in connection with Customer programs and in case you are a winning participant in Games organized by “KLIMATI HOLIDAY” Ltd.
    “KLIMATI HOLIDAY” Ltd. does not collect personal data from its customers unless they contact us directly. In order to respond adequately to customers’ inquiries, it is possible that personal data may be shared with third parties.

3.1.3. Other data collected automatically
We collect data automatically through the Website. However, if we combine your personal data with those we collect automatically (e.g., geographic location from your IP address and we combine it with behavioral information about your use of the Website, with your name), we treat the information as personal.
“KLIMATI HOLIDAY” Ltd. and its online advertising and marketing partners may use various technologies to collect information, including:

3.1.4. Cookies
Like many other websites, we use devices that collect data such as “cookies”. We collect these data for the purpose of analyzing page traffic and to measure the effectiveness of the promotions we offer. A cookie is a text string of information that the Website sends to the cookie file of the browser on the hard drive of your computer so that the Website can remember you.
The cookie usually contains the name of the domain from which the cookie came, the “lifetime” of the cookie and a value that usually represents a randomly generated unique code.
This helps us provide you with better use of our Website and also allows us to improve the services we offer.
A few important things you should know about cookies:
“KLIMATI HOLIDAY” Ltd. offers certain features that are accessible only through the use of cookies.
• they are used to improve the use of the Website;
• most cookies are “session cookies”, which means that they are automatically deleted from your hard drive at the end of the session.
You have the option to accept or refuse cookies by changing your browser settings. If you refuse cookies, this may prevent you from using all the interactive features of the Website.

3.1.4. Internet Protocol (“IP”) Addresses
The IP address is associated with your computer or your mobile device. “KLIMATI HOLIDAY” Ltd. may use your IP address to help diagnose problems with the “KLIMATI HOLIDAY” Ltd. server, administer the Website and maintain contact with you while you use the Website.

3.2. Potential employees
If you wish to be part of the team of “KLIMATI HOLIDAY” Ltd. and submit an application for employment or attach your CV, we process and store the personal data entered in the specified documents for a period not longer than 6 months after completion of the selection process. The collected personal data may include, but are limited to:
• Identification: names, address, telephone number, e-mail address, date of birth, citizenship, bank account;
• Education and professional qualification: data related to education, work experience, professional and personal qualifications and skills, when necessary and required for the position.
These personal data are stored in accordance with the personal data privacy rules provided when applying for a job at “KLIMATI HOLIDAY” Ltd.

3.3. Employees
With respect to its employees, “KLIMATI HOLIDAY” Ltd. processes the following personal data:
• Identification: three names, personal identification number, date of birth, permanent address, education and professional qualification; professional experience, bank account number;
• Data concerning health status, including a medical certificate for all employees and data from the personal health booklets of employees working directly with food;
• Data concerning criminal record – criminal record certificate.
These personal data are stored in accordance with the internal rules for personal data protection of “KLIMATI HOLIDAY” Ltd. and the Employees’ Personal Data Privacy Notice.

3.4. Contractors and suppliers
With respect to our suppliers of goods and services who are natural persons / as freelancers / and the representatives or contact persons of our suppliers of goods and services who are legal entities, “KLIMATI HOLIDAY” Ltd. processes the following personal data:
• Identification: names, personal identification number, address, telephone number, e-mail address, date of birth;
• Professional activity: position, official capacity;
These personal data are stored in accordance with the internal rules for personal data protection of “KLIMATI HOLIDAY” Ltd. and the Privacy Notice for suppliers and partners.

3.5. Visitors to premises
With respect to persons visiting premises of “KLIMATI HOLIDAY” Ltd. where video surveillance is carried out, “KLIMATI HOLIDAY” Ltd. processes the following personal data:
• Identification: voice data and video image;
These personal data are stored in accordance with the rules for personal data protection in video surveillance and monitoring of “KLIMATI HOLIDAY” Ltd.

  1. How we collect the data

Clients
The Company usually collects and processes the personal data of clients in the preparation, drafting and provision of a reservation and accommodation in the facilities of “KLIMATI HOLIDAY” Ltd.
The Company usually does not process clients’ personal data in the preparation and sale of drinks and food in its establishments.
Clients’ personal data are processed when the client decides to participate in one of the programs or games organized by the Company. In such a case, the clients’ personal data (the processed personal data may include, depending on the specific case, the client’s first and last name, current address, e-mail address, date of birth, telephone number, payment data and, where applicable, information about the order and places of purchase) are processed solely with the consent of the client, provided voluntarily in accordance with the rules of the relevant program and game.
Clients’ personal data are processed within customer programs for the purposes of facilitating the fulfillment of the orders of the respective client, for marketing (e.g. as part of the company’s marketing campaigns, for providing information about new products, for delivering commercial messages of the Company or for notifying about prizes won or other winnings of the client) and for the purposes of tracking customer satisfaction.
Clients’ personal data (the processed personal data may include, depending on the specific case, the client’s first and last name, current address, e-mail address, date of birth, telephone number, payment data and, where applicable, information about the order and places of purchase) are also processed in cases of contact by a client with the company in connection with expressing opinions, complaints, suggestions, objections, etc.

Website users
The Company uses cookies on its Website. Cookies provide faster and more efficient browsing of the Website and adapt the display of products and other content to the personal interests and specific needs of the User. Cookies are used to collect accumulated anonymous statistical data, allowing understanding of the way the Website is used and enabling optimization of its structure and content, as well as to provide certain functions of the Website and personalize advertisements.
The Company uses two types of cookies – temporary (session) and persistent cookies. Session cookies are used temporarily and are stored on the User’s device until the moment they leave the Website or close the application (web browser). Unlike them, persistent cookies remain on the User’s device for the time specified in the parameters of the respective cookie or until the User deletes them.
The information obtained through the use of cookies can be collected only for the purposes of mediation and performance of certain user functions. These data are encrypted in a manner that prevents access by unauthorized persons.
Usually, the application used to browse the Website allows storing cookie files on the User’s device according to the initially set settings. This mode may be changed either by completely blocking cookies in the web browser settings or by partially blocking them – in which case the User is notified each time the device stores cookies. More detailed information about the possibilities and ways to manage cookies is available in the settings of the application (web browser).
The Website collects information about the User’s IP address (i.e., the number that unequivocally identifies the network interface of the User’s computer network), the domain name, as well as the type of web browser and operating system. The purposes of processing these data are similar to those of cookies, which means that these data are used by the Company to collect statistical data for analyzing the use of the Website and for personalizing advertisements.
The personal data of Users are processed in the presence of consent, provided voluntarily by the User by loading the Website or by default is expected in connection with the use of the Website.
The personal data of Users who register or send an inquiry on the website are processed in the presence of consent, provided voluntarily by the User when performing the registration or inquiry.

Employees and Potential employees
The Company processes the personal data of employees and potential employees within the scope necessary for selection and hiring of staff and for fulfilling legal obligations (e.g. the obligation to withhold or pay taxes, to keep files for the purposes of health and social insurance, etc.). The employee undertakes to provide these data to the Company. Failure to provide these data should be considered a violation of legal prescriptions by the employee and/or the Company and may lead to sanctions imposed by the competent state authorities.
The Company processes employees’ personal data separately from legal requirements only with their consent and as part of verifying the legitimate interests of the Company or performing the contract concluded by and between the Company and the employee, specifically for the purposes of processing personal data in the CVs of job candidates for the Company, preparing advertising materials, managing the Company’s profiles on social networks, storing records of the use of company cars, providing information about Company events, protecting the Company’s property (mainly the use of video surveillance systems) or providing access of authorized persons to the Company’s premises.

  1. What we do with the personal and other data we collect
    First of all, we use the data you provide to us or that we collect to provide you with the products, services or information you have requested. We also use the data to improve functionality when using our Website.
    It is possible that we may use your data to provide you with information regarding products or services that may be of interest to you. In order to automatically address customer inquiries and to provide the services offered through our Website, it is possible that we share information with our service providers.
  2. Choice
    You have the right to opt out of certain use and disclosure of your personal data as set out in this Policy. Before disclosing sensitive data to a third party or processing sensitive data for a purpose other than the original purpose or the purpose subsequently authorized by you, “KLIMATI HOLIDAY” Ltd. will make the necessary effort to obtain your explicit consent. Where consent for data processing is required by law or contract.
    If you participate in any promotion, the personal data you provide will be processed in accordance with the privacy rules applicable to that promotion, to the extent that they differ from this Policy.
  3. Where we store your personal data
    All personal data sent and collected through the websites are stored on our servers, on shared servers, on the servers of other controllers or processors of personal data with whom “KLIMATI HOLIDAY” Ltd. has staff recruitment contracts, or on the servers of our suppliers of goods and services. By using our websites, you agree that we store your data at the specified locations.

7.1. Provision of data to third parties
The Company provides already processed personal data only to partners with established technical and organizational measures for data protection and fulfillment of other obligations arising from Regulation (EU) 2016/679 of the EU of 27.04.2016 and the PDPA regarding data protection. The Company’s partners have access to personal data only within what is necessary to fulfill their obligations. Therefore, the Company, in certain cases, provides personal data to other companies and third parties that provide services to the Company related to the hosting of personal data on shared servers, the management of loyalty program applications, ensuring payments for purchases from the Company and analyzing marketing research. The personal data of the Company’s employees are provided to the external accounting company which collects accounting and tax archives and payroll records of the Company and, in some cases, to companies providing services to the Company that allow the Company’s employees to report cases of violation of legal provisions or in cases where the Company, its partners or its employees act unethically.
Under no circumstances does the Company provide personal data to third parties in exchange for payment.

7.2. Transfer of personal data to third countries
The Company may transfer personal data to countries outside the European Union and in certain cases to third countries (USA), regardless of whether there is a decision of the European Commission on the level of protection of personal data in these third countries, equivalent to that existing in the European Union.
The transfer of personal data to other companies and third parties is carried out, if necessary, on the basis of a contract under which the recipient of personal data undertakes to maintain high standards of personal data protection (the transfer of personal data is based on the “standard clauses” for the protection of personal data pursuant to Article 46(2)(c) of the General Data Protection Regulation) and/or subject to the consent of the person whose personal data are transferred.
Retention period. The personal data you provide will be stored for a period no longer than necessary to achieve the purposes for which they are processed.

  1. How we protect your data
    “KLIMATI HOLIDAY” Ltd. applies organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of the processing of personal data.
    Among other things, such security measures include the following activities:
  • “KLIMATI HOLIDAY” Ltd. has established the requirements for processing, registration and storage of personal data with internal procedures, the compliance with which is constantly monitored;
  • access of employees of “KLIMATI HOLIDAY” Ltd. to personal data and authorization to process personal data in the database of “KLIMATI HOLIDAY” Ltd. is restricted depending on their duties;
  • “KLIMATI HOLIDAY” Ltd. has established confidentiality obligations for its employees;
  • access to the office equipment of “KLIMATI HOLIDAY” Ltd. and the computers of each employee is restricted;
  • we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as the best practices from international standards;
  • for maximum security in processing, transfer and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.
    The security measures we apply are subject to constant improvement and adaptation to the most modern technologies.
  1. Access
    Where the law permits, you may use any of the methods in Section 13 of this Policy to obtain confirmation that “KLIMATI HOLIDAY” Ltd. processes personal data about you and to request access, correction or deletion of personal data processed by us, including where the data have been processed in violation of the principles of Regulation (EU) 2016/679 of the EU of 27.04.2016 and the PDPA. Such requests will be processed in accordance with the internal rules of “KLIMATI HOLIDAY” Ltd., consistent with Regulation (EU) 2016/679 of the EU of 27.04.2016 and the PDPA.
    “KLIMATI HOLIDAY” Ltd. respects and takes due care to comply with the rights of data subjects, but there may be cases where it is impossible to provide the requested information, for example, but not only:
  1. where the law takes precedence over the rights of the data subjects;
  2. where it would pose a risk to the security of the data subjects;
  3. where it would interfere with the privacy of other persons or where it is commercial property.
    If the Controller determines that access must be restricted in any particular case, “KLIMATI HOLIDAY” Ltd. will make the necessary efforts to notify you of the reasons that led to restricting access to the information you requested, and will provide you with contacts for further inquiries.
    If necessary, the Data Protection Officer of “KLIMATI HOLIDAY” Ltd. will contact another person to cooperate and complete the process of providing the data you requested. To protect your data, the Controller will take the necessary steps to confirm your identity before providing access to or making any changes related to your data.
  1. Data integrity – purpose limitation
    “KLIMATI HOLIDAY” Ltd. processes the personal data it receives while you use the sites or while it is necessary to complete the purpose(s) for which they were collected, for example, but not only: until completion of the provided services, for dispute resolution, for legal protection, during audits, in the presence of legitimate business interests, for performing agreements and for compliance with applicable laws. Your consent for these purposes is not required.
  2. Further sharing
    “KLIMATI HOLIDAY” Ltd. does not provide personal data to third parties unless a client or potential employee requests it or has given consent for such disclosure, or disclosure is required by law. The Controller may share personal data with its service providers, consultants and affiliates for internal, business purposes or to supply you with a product or service you have requested.
    Payment information will be processed only to fulfill the order; it is possible that it may be stored by our service provider for the purposes of future orders or for accounting reporting purposes.
    The Controller requires from its suppliers or other personal data processors written consent for confidentiality and for ensuring the protection of personal data they maintain on behalf of the Controller, including ensuring at least the minimum level of protection required by the principles of Regulation (EU) 2016/679 of the EU of 27.04.2016, the data not to be used for any purposes other than those specified by the Controller. Suppliers must notify the Controller if they have determined that they can no longer fulfill their obligations. With regard to further transfers of data provided to third parties, the Controller monitors the manner of processing of personal data by requiring a guarantee from the processing party that it complies with the principles of Regulation (EU) 2016/679 of the EU of 27.04.2016.
    Your personal data are considered an asset of the company and may be disclosed or transferred to a third party in the event of a change in the legal organizational structure of “KLIMATI HOLIDAY” Ltd., for example in any reorganization, sale, merger, division, joint venture, transfer, consolidation or other type of acquisition, disposition, or financing of all or part of our business, or of certain business assets or shares (including in connection with insolvency or similar proceedings). In such cases, your data are transferred to a third party so that you can continue to receive the same products and services or to maintain the same relationship with the third party.
    Although we make all necessary efforts to maintain the confidentiality of the personal data we collect, “KLIMATI HOLIDAY” Ltd. reserves the right to disclose personal data to third parties under certain limited circumstances, including: (a) compliance with a law, search warrant, subpoena, court proceeding, judicial or administrative order; (b) response to a legal request by public authorities, including to meet national security requirements or law enforcement requirements; (c) enforcement of the Controller’s policies or agreements; (d) collection of amounts due; (e) protecting users of the sites from fraud or abuse; (f) during emergencies when safety is at risk, as determined by the Controller; (g) where necessary to establish, exercise or defend legal claims.
    By decision of the Controller, server logs may be reviewed for security purposes, for example to detect unauthorized activity on the sites. In these cases, server data containing IP addresses will be shared with law enforcement agencies so they can identify users in connection with their investigation of unauthorized activities.
  3. Security
    Although there is no such thing as “guaranteed security”, we and our partners use commercially reasonable measures (including all steps required by applicable law) designed to protect your personal information from loss, unauthorized access, use, alteration, disclosure or other misuse.
  4. Rights of data subjects
    You may also submit a complaint to your Supervisory Authority; for Bulgaria this is the Commission for Personal Data Protection, at the addresses specified in this Policy. “KLIMATI HOLIDAY” Ltd. will fully comply with the recommendations given by the Supervisory Authorities and will take the necessary steps to remedy any non-compliance with regulatory principles.
    Commission for Personal Data Protection,
    address: Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2;
    website: www.cpdp.bg.
    If you suspect a violation of legal requirements, you have the right to file a complaint with the supervisory authority for personal data protection:
    Your legal rights are:
    • To request information as to whether we process your personal data, what they are and for what purpose they are processed.
    • To request access to your personal data (“Data access request”). Allows you to receive a copy of the personal data we hold and to verify whether we process them in accordance with the established legal procedure.
    • To request correction of your personal data held by us. You have the opportunity to correct any incomplete or inaccurate information we hold about you.
    • To request deletion of your personal data. Allows you to ask us to delete or remove personal data if:
  • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;
  • the data subject objects to processing, including profiling, and there are no overriding legitimate grounds for the processing, or the data subject objects to processing for direct marketing purposes;
  • the personal data have been processed unlawfully;
  • the personal data must be erased to comply with a legal obligation under Union or Bulgarian law;
  • the personal data were collected in connection with the offer of information society services.
    • To object to processing against certain types of processing, such as direct marketing (unsolicited advertising messages), as well as where processing is based solely on the Controller’s legitimate interest.
    • To object to automated decision-making, including profiling, i.e., not to be subject to any automated decision-making by us through your personal data or profiling.
    • To request restriction of the processing of your personal data when:
  • you contest the accuracy of the personal data for a period enabling the Controller to verify the accuracy of the personal data;
  • the processing is unlawful, but the data subject does not want the personal data to be erased and instead requests restriction of their use;
  • the Controller no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defense of legal claims;
  • you have objected to processing based on the Controller’s legitimate interest, pending verification whether the legitimate interests of the company override those of the data subject.
    • To request transfer of your personal data in electronic and structured form to you or another person (commonly known as the right to “data portability”). This allows you to receive your data from us in a usable electronic format and to transfer them to another person in a usable electronic format.
    • To withdraw your consent. In the rare cases where you may have given consent to the collection, processing and transfer of personal data for a specific purpose, you have the right at any time to withdraw your consent regarding that specific type of processing. After we receive notice that you have withdrawn your consent, we will stop processing your information for the purposes to which you originally agreed, unless there is another legitimate reason for us to do so by law.
    The request may be made by completing a Request Application and sending it to the e-mail address of the Data Protection Officer or to the address of “KLIMATI HOLIDAY” Ltd.
    In order to be sure that we have identified the exact person, it is possible that we will contact you to confirm your request.
    “KLIMATI HOLIDAY” Ltd. undertakes to examine your request without undue delay and in any case within 30 days of receiving the request. In cases involving legal and factual complexity, this period may be extended by a further 30 days. You do not need to pay a fee to exercise the above rights. In the event of a repeated request on the same grounds, if the request is manifestly unfounded or excessive, a fee may be charged.
    In order to provide complete, accurate and clear information in the Request, it is possible that we may ask you for specific identifying data that will help us confirm your identity. This is an additional security measure ensuring that your personal data will not be disclosed to persons who are not entitled to receive them.
  1. Information concerning children
    We do not knowingly collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person with parental responsibility for the child.
    If you are a parent or legal guardian of a child who you think has provided us with personal data, please contact our data protection officer and they will take immediate action to delete the information in accordance with applicable law.
  2. Links to third-party sites
    Please note that the Website may contain links to other websites for your convenience and information. The Controller does not control external sites outside the company, nor their privacy practices. Please note that they may differ from those set out in this Policy. “KLIMATI HOLIDAY” Ltd. does not endorse and makes no representations regarding third-party websites. Personal data that you choose to provide to unaffiliated websites are not covered by this Policy. We encourage you to review the privacy policies of other websites before providing your personal data. Some third parties may choose to share their users’ personal information with us. Such sharing is governed by the company’s privacy policy and not by this Policy.
  3. Changes to the Privacy Policy
    The Controller may update this Privacy Policy. When the Policy is changed, we will update the “last revision” date located at the very top of the Policy.
    If there are any changes to this Policy, we will notify you of this. We encourage you to read our Privacy Policy so that you are informed how we protect the information provided by you.
    If you continue to use the Website after the publication or amendment of the Policy, this will be considered as your consent to be bound by it and all such changes to it.
    Any change to this Privacy Policy takes effect immediately upon its publication.
  4. Other related policies
    This Policy may be supplemented with one or more special policies or privacy notices. In the event of a conflict between this Policy and any special policy, the applicable special policy shall prevail.

In addition, you have the right to file a complaint with the Commission for Personal Data Protection: Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2 or in electronic form on the Commission’s website https://www.cpdp.bg.

This policy is approved and enters into force as of September 2023.

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