GDPR Protection of Personal Data
The protection of personal data is important to Union Ivkoni Ltd. The company has adopted a number of internal rulesfor the protection of the personal data of its clients.
The purpose of the present information is to inform the CLIENT and the other persons who use the services of Union Ivkoni Ltd. for transportation of passengers in accordance with the General Terms and Conditions, irrespective of whether the service is requested via the onlinesystem personally by them or on their behalf (referred to below as common „Clients”). Also, the clients shall be notified on the type of personal data processed by Union Ivkoni Ltd., the reasons due to which it processes such data and provides it to third parties, the duration of the storing of such data, the rights of the Clients with regards to the protection of their personal data and the manner in which these rights can be put to use.
In case that the CLIENT requests services of transportation of passengers on behalf of and in favour of other subjects and for these purposes he or she provides personal data with regards to them, the CLIENT is obliged to inform these subjects about the present conditions.
1. Categories of Processed Personal Data
Union Ivkoni Ltd. collects and processes personal data by other means as long as this is necessary in the scope of activities performed by it and for the purposes of provision of high quality services.
During the use of the online system for bus ticket selling for transportation of passengers on the regular lines of Union Ivkoni Ltd., the company processes the following categories of personal data:
- identifying information:three names / respectively, a name and a surname; EGN (PIN) / Personal Number of a Foreigner / date of birth; IP address;
- contact infromation:e-mail address; telephone number;
- number of a discount card (if you have such card);
- data related to your habits and preferences:
- data related to the use of services provided by Union Ivkoni Ltd. (e.g., in accordance with the use of a card for discounts);
- You can find more information HERE;
- personal data necessary for the undertaking of steps on the request of the CLIENTS before the conclusion of a contract for the transportation of passengers;
- other personal data that are or may become necessary for the purposes of the use of the online system for bus ticket selling for transportation of passengers on the regular lines of Union Ivkoni Ltd. and/or the services that accompany them, and which are imperative in accordance with the applicable legislation;
2. Bases and purposes for the processing of personal data by Union Ivkoni Ltd.
Union Ivkoni EOOD processes (collects, stores and uses) personal data regarding Clients on the basis of one of the bases provided below, in view of the achieving of one of the purposes listed below:
a. Implementation of legal and regulatory obligations of Union Ivkoni Ltd.
Union Ivkoni Ltd. processes personal data regarding its Clients in order to comply with numerous legal and regulatory obligations related to the services provided by it, including, but not limited to:
- Performance of transportation on regular bus lines within the territory of the Republic of Bulgaria and outside of it;
- Compliance with the legislation related to sanctions and/or measures for security;
- Reply to official question sent by a duly authorized public or court authority.
b. Performance of a contract concluded with or in favour of the Clients, or with regards of the undertaking of stepts on the basis of the request of persons that are subjects of the data, before the conclusion of a contract
Union Ivkoni Ltd. processes personal data for the purposes of conclusion and performance of contracts for transportation, as well as with regards to the performance of the rights and obligations under the present General Terms and Conditions, as well as in order to provide information regarding the services, with regards to which certain potential Clients have claimed that they are interested in (e.g., receipt of a confirmation of a successful rezervation via mail, through the online system for bus ticket selling for transportation of passengers on the regular lines of Union Ivkoni Ltd.), as follows:
- Establishment of relations with new Clients;
- Conclusion, performance and termination of contracts;
- Provision of discounts;
- Communication with Clients.
c. Purposes related to the legitimate interests of Union Ivkoni Ltd., as follows:
- Internal accountancy;
- Recovery of claims;
- Activities of checking in case of complaints.
If it is necessary for Union Ivkoni Ltd. to perform additional processing for purposes that are different that the ones that are set out in Section 2 of the present part of the General Terms and Conditions above, Union Ivkoni Ltd. shall inform its Clients about that when the receipt of their consentis necessary for that matter.
Due to the nature of the type and volume of the collected personal data described above, during the use of the online system for bus ticket purchasing, in case of not providing any or all of them, Union Ivkoni Ltd. may happen to be unable to provide the requested service.
3. Categories of Receivers of Personal Data
For the purposes of the achieving of the abovementioned purposes, Union Ivkoni Ltd. discloses personal data with regards to the Clients to:
- Service providers that perform services on behalf of Union Ivkoni Ltd. during or for the purpose of use of the online system for bus ticket selling for transportation of passengers on the regular lines of Union Ivkoni Ltd.;
- Independent agents or intermediaries during or for the purpose of use of the online system for bus ticket selling for transportation of passengers on the regular lines of Union Ivkoni Ltd.;
- Commercial partners during or for the purpose of use of the online system for bus ticket selling for transportation of passengers on the regular lines of Union Ivkoni Ltd.;
- Public or court authorities, on the basis of a request, in and up to the volume that is permitted according to the law;
- Other administrators, on behalf of which Union Ivkoni Ltd. processes personal data or which happen to be joint administrators along with Union Ivkoni Ltd.;
- Persons, who perform services of provision and maintenance of equipment, software and hardware, used for the processing (storage included) of personal data, for the purposes of accountability of payments, etc.
4. Transmitting of Personal Data Outside of the European Economic Area (EEA)
Union Ivkoni Ltd. may perform international transmission of data that originates from EEA,when the European Commission has acknowledged a certain country outside of the EEA as a country that provides an adequate level of data protection.
For transmitting to countries outside of EEA, the level of the protection of which is not acknowledged by the European Commission, Union Ivkoni Ltd. shall refer either to a certain derogation that is applicable to the concrete situation in accordance with the Regulation (e.g., if the transmission is necessary for the performance of a contract of Union Ivkoni for transportation of passengers), or it shall apply one of the guarantees that are provided in the applicable legislation.
In all other cases, with regards to the transmitting of personal data to countries outside of EEA, it shall be performed on the basis of an explicit consent by the Clients for the offered transmission of data. In these cases, the necessity of such transmission, the country to which the transmission will be made, as well as the lack of decision of the European Commission for an adequate level of protection with regards to this country and of suitable guarantees during the offered transmission, shall be brought to the knowledge of the Clientsand their consent shall be requested.
5. Period of Storage of Personal Data
Union Ivkoni Ltd. shall keep the personal data regarding the Clients during the longer period of the following periods: either the periods that are necessary for the compliance with the applicable laws and the subregulatory acts, or for another period in accordance with the requirements applicable towards the activity of Union Ivkoni Ltd. The processing of the personal data is based on the principal of minimisation of data depending on and for the purposes of provision of the services that the relevant Client uses (e.g. a discount for children and/or people over a certain age (ENG (PIN)), use of the online system of Union Ivkoni Ltd. for purchasing tickets (IP address; email; telephone number; data related to the habits and preferences, etc). Part of the data may be stored after the finishing of the service requested by the Client, for the purposes of the provision of discounts for regular clients, for the performance of legal obligation of Union Ivkoni Ltd. or for the purposes of the legitimate interests of the company.
6. Rights of the Clients with Regards to the Protection of the Personal Data and Manner for the Performance of These Rights
In accordance with the applicable regulatory requirements, the Client is entitled to:
- receive information upon the collection of the personal data from himor her, or from third parties;
- right of access to the his or her personal data and more concrete: (i). a confirmation whether any personal data of him or her are being processed by Union Ivkoni Ltd.; (ii). the provision of access to the data via a copy of the data, which are being processes at that time, as well as information regarding the purposes of the processing; the categories of personal data; the receivers or the categories of receivers to whom the personal data are disclosedor will be disclosed; the terms for the storing of the personal data;the existence of a right of correction in or deletion of personal data or limitation of the processing of personal data, or objection against the processing; the right of filing of a complaint with a Monitoring Authority (which, in the Republic of Bulgaria is the Commission for Personal Data Protection), orthe sources of personal data; the existence of automatized adoption of decisions, including by profiling;
- right of making corrections–to require the making of corrections or the filling of his or her personal data in case that the latter are not correct or are incomplete;
- right of deletion of personal data when the bases for this that are set out in the applicable legislation are present;
- right of limitation of the processing;
- right of data transfer;
- right of objection;
- right of the Client to not be a subject of decision that is solely bases on an automatized processing, including profiling, which causes legal consequences or affects him or her in significant volume in another way;
- provision, change or withdrawal of consent for processing of personal data, when the basis for the processing is the constent of the Client.
The Clients can perform their rights by filing a written application with Union Ivkoni Ltd. in one of the following manners:
• personally, by a legal representative or via a representative of the Client that is authorized with a Power of Attorney certified by a notary public, in the office of Union Ivkoni Ltd. situated at the following address: Sofia, 102 Kn. Maria Luiza Blvd., Serdika Bus Station, floor 2 , after an identification of the subject of data or of the relevant representative performed by an employee of Union Ivkoni Ltd.;
• via electronic mail sent to the DPO by using a qualified electronic signature in accordance with the Law on the Electronic Document and the Electronic Certification Services;
• via mail by sending an application that has been certified by a notary public for the purpose of indentification of the applicant.
7. Amendments with regards to the Personal Data Protection
Union Ivkoni Ltd. shall inform the interested parties about any significant amendments in these terms and conditionsvia its website or via other common channels for communication.
8. Contact with Union Ivkoni Ltd. with Regards to the Protection of Personal Data
If our Clients have any questions related to the processing of personal data in accordance with the present General Terms, they can contact the Data Protection Officer of Union Ivkoni at the following e-mail address: email@example.com.
You can find more infrormation about GDPR policy HERE.