Last updated as at: 16.10.2020 г.
1. Personal Data Controller
SAN STEFANO PROPERTY DEVELOPMENT EAD, UIC 130465134 (hereinafter referred to as SSPD, the Controller, we, us) manages and administers the Website www.sspluxuryapartments.com and is the Controller of the personal data collected and processed through it.
In order to be most useful through its Website, in certain cases SSPD processes personal data of users of the Websiteand in that capacity is a personal data Controller within the meaning of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
The security of your information is an important part of the SSPD`s internal policy. As a Controller SSPD considers as a matter of priority the issues of protection of your personal data collected during your visit of our Websiteand the processes of their processing and storing in compliance with the legal requirements.
2. Contact with the Controller
You can contact us with any questions regarding the processing of the personal data provided by you through our Websiteand the exercise of your rights with regard to this processing. You may contact us by any of the following means:
- in writing at the following address: 22 San Stefano Str., 1504Sofia;
- by telephone number: +359 2 846 40 70;
- via Website: www.sspluxuryapartments.com .
3. Personal Data We Collect About You. Purposes and Grounds for Their Processing
The use of the information from our Websitedoes not imply the provision of any personal data by you.
The Website contains the following functionalities through which SSPD may collect and process your personal data:
3.1. Sending an Inquiry
The personal data collected and processed by the SSPD through the option for asking questions “Send us an email” in the Contacts section are: your names (name and surname), email address and other data that you have decided to provide us with in your inquiry.
Your personal data is collected and processed:
Личните Ви данни се събират и обработват:
- For the purpose of sending a reply to the inquiry you have sent us.
The legal basis for the processing of your personal data in this case is your explicit, voluntary consent, which we consider that you have provided by sending us the inquiry. SSPD will process your personal data only for the time required to prepare and send a reply to your inquiry and within 3 months of our last correspondence with you, unless you become an owner or a tenant of a property in Multifunctional complex San Stefano Plaza, in which case, the terms of the agreement signed between us shall be applied to the processing of your personal data;
- We may use these data for direct marketing purposes as well – to inform you for the products and services offered by SSPD or to invite you to events organized by us.
3.2. Other Collected Data
Besides the personal data, specified above and collected by SSPD upon using certain functions of the Website, other data may be processed additionally.
SSPD uses “Cookies” and other tracking technologies, which collect information about you upon interaction with our Website, so that we can improve its performance and functionality.
Cookies are small files that may be saved on your computer or mobile device when you visit a Website. The Cookie will help the site or other websites to recognize your device the next time you visit it. Web beacons or other similar files can do the same thing. In this Policy we use the term cookies to designate all files, which collect information in such a manner.
4. Consequences of Non-provision of Personal Data
When you intend to send us an inquiry, the provision of the data by you is entirely voluntarily.
In case you do not want to provide us with your personal data you will not be able to receive the desired services - we will not be able to reply to your inquiry.
5. Disclosure of Your Personal Data
SSPD may provide your personal data to the following categories of recipients:
- state authorities, to which we are obligated by law to provide personal data;
- the company, which by SSPD’s assignment maintains this Website.
6. Your Rights with Regard to the Personal Data Processing
In relation to the processing of your personal data by SSPD you are entitled to various rights in order to protect your interests. All rights listed hereinbelow (with the exception of the right to lodge a complaint with a supervisory authority) you can exercise by filing a request to us. SSPD will make all necessary efforts to satisfy your request without unnecessary delay.
- Right of access:
A main right of yours is at any time to receive a confirmation by SSPD whether your personal data are being processed, as well as to be provided with access to the processed data and information regarding the processing purposes, the categories of personal data that are being processed, the recipients of your personal data, the processing period, the presence of automated decision-making and your rights with regard to the processing.
- Right of rectification:
When you consider that the personal data processed about you are inaccurate you have the right to request SSPD to correct them, as well as to request to have your incomplete personal data completed.
- Right of erasure:
As a subject, whose personal data are being processed by SSPD you are entitled to request from the Controller their erasure in the following cases:
а) your personal data are no longer necessary for the purposes, for which they have been collected and processed;
b) withdrawal of your consent, on the basis of which your personal data have been processed;
c) your personal data are being processed unlawfully;
d) you have objected against the processing of your personal data and there are is legal basis for the processing, which shall prevail;
e) the personal data must be erased for the purpose of compliance with the legislation of the European Union or of the Republic of Bulgaria.
- Right of restriction of the processing:
Another right of yours with regard to the processing of your personal data by the SSPD is to request, as far as the legal requirements are met, the restriction of the processing of your personal data by SSPD in the following cases:
а) you dispute the accuracy of the personal data – for a period that allows SSPD to verify the accuracy of your data;
b) the processing of your personal data is unlawful, but you do not want your personal data to be erased but only to restrict their use;
c) SSPD no longer needs your personal data for the specified purposes, but you require that the restriction of their processing is ensured, for the purposes of establishment, exercise or defense of legal claims.
- Right of objection to the data processing:
As far as your personal data are subject to processing by SSPD you are entitled to object at any time against this processing. In this case SSPD will stop the processing of your personal data, unless there is another legal basis for their further processing, such as compliance with legal requirements or there are other legitimate interests present that require the continuation of the processing.
- Right of withdrawal of your consent:
The processing of your personal data by SSPD based on your explicit consent for that can be terminated with the withdrawal of your consent. This right of yours has immediate effect, however, it does not affect the lawfulness of the processing of your personal data performed up to the moment of the withdrawal of your consent.
- Right of data portability:
You are entitled to receive a copy of your personal data that you have provided to SSPD, including, when possible, in electronic form. When the processing of your personal data is based on consent or on a contractual obligation and is performed in an automated manner, you can make a request to SSPD to receive the personal data in a structured, widely used, machine-readable format. In this regard you can also request SSPD to transfer these data directly to another personal data controller upon your instruction.
- Right of complaint with a supervisory authority:
If you consider that your personal data are being processed unlawfully or that your rights in connection with them have been violated, you are entitled to lodge a complaint with the competent Bulgarian supervisory authority – The Commission for Personal Data Protection (the CPDP). You may contact the CPDP by using the following contact details:
Address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia
7. Changes in the Present Policy