PRIVACY POLICY
Your privacy is important to us and we are committed to protecting it and keep your trust. We respect your privacy and we keep your security when you visit our website (http://sac.bg), fill in our forms or you participate our public events. Therefor, we have adopted this Privacy Policy which explains what personal data Sofia Airport Center collects from you, through our direct interactions with you and through our services, how we use that data, and what rights you have according to the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of this data (General Data Protection Regulation / GDPR) and how you can exercise those rights.
Please, read carefully our Personal Data Policy when you disclose your personal data.
When you accept our Personal Data Policy under terms and conditions described herein below, you voluntarily agree to your personal data being processed in accordance with the purposes set out hereto.
Personal Data Controller of your personal data is Sofia Airport Center EAD, a Single-Member Joint-Stock Company, UIC 131006529, having its seat and address of management in Bulgaria, Sofia, 1172, 58 G.M. Dimitrov Blvd., fl. 3, Nikolina Stefanova, contact details: ns@cerescee.com, tel. 02 / 492 3800, („Controller” or „Sofia Airport Center”).
Personal Data
Personal Data shall be any information that we collect about you and based on which you can be identified. Generally, all the information you provide during your registration for our services shall be Personal Data and we will protect as Personal Data.
This Privacy Policy describes how we process your personal data. When we refer to the ‘processing’ of your personal data, we mean anything that we do with your data, including its collection, recording, organization, structuring, storage, adaptation or alteration, use, disclosure erasure or destruction. We will always strictly observe the requirements of the applicable data protection laws when processing your personal data.
You are not obliged and there is no legal obligation imposed on you for providing your personal data, therefore we will process only information provided by you based on your informed and voluntary willingness.
Information for your access to the web site
When you access our website and its menus, we will receive information about you in the form of information protocol with the following content:
- Web site which has directed you to our web site;
- IP-address;
- Date and length of the access;
- Quantity of data transfer;
- Information for your browser and operating system.
Information related to the contact form of the website
In case you wish to send inquiry through the "Contact form" functionality available on the Website, you will be asked to provide information about:
- your name,
- phone number,
- email,
we will use these details to contact you if necessary to answer your inquiry.
Information in public events
In case you attend our public event (by using our website (http://sac.bg), or on the territory of Sofia Airport Center) we may process your personal data:
- name,
- picture,
- age,
- marital status,
- profession,
- education,
- e-mail,
- personal preferences, and
- other information specified in the terms and conditions of the event.
Your personal data shall be processed in relation to these events only if they are voluntary provided by you. When you attend our event or initiative you understand and agree that we may process your personal data related to your participation, as well as we may use them in publications related to the event on our website or in our social media. You will always be informed when entering any of our events if there is ongoing video recording on premises. We may use the visual or video captures of your person on our websites or promotional material for marketing purposes. Under no circumstances will we associate your personal information (such as your name) with your image.
You are entitled to contact us at any time in order to ask for deletion of your personal data, by e-mail to: ns@cerescee.com. Detailed terms and conditions regarding our public campaigns and events are specifically provided for each event.
Personal data collection
We collect and use only personal data provided by you voluntarily in accordance with the provisions of this Privacy Policy.
Legal ground and purposes of processing
Consent: We process your personal data based on your explicit consent which you provide by sending us an enquiry from the Contact form or when subscribing to our Newsletter. You can withdraw your consent at any time through the contact information incorporated in the section “Contact Form”, or where relevant, by following the unsubscribe button/link in your email or by contacting us. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful. If you choose to withdraw your consent for the processing of your personal data for the delivery of our services, we will no longer be able to cooperate with you.
Legitimate interests: We also process your personal data based on our legitimate interests when we video record the physical events organized by us so that we can use the photographs or the video recordings in order to promote our future events. We will never associate your visuals with the other personal information we have on you. Yet, you may object at any time against us processing your personal data for marketing purposes by contacting us through the contact information incorporated in the section “Contact Form”.
Legal obligations: Your personal data is also in certain situations processed in order for Sofia Airport Center to comply with its legal obligations according to the applicable legislation, court rulings, or decisions taken by the authorities.
We will use only personal data provided by you voluntarily in accordance with the legal ground and purposes of processing described hereto.
The information protocol and data therein shall be processed for the purposes of the security of our IT system and the restriction of unauthorized access to our website, incl. hacker attacks, to protect our legitimate interests in maintaining the security of our IT system.
Your personal data related to your inquiry through the contact forms on the website will be processed only for the purposes for which we collect them, including to respond to your inquiries and communicate with you in this regard, based on your voluntary explicit and informed consent to the processing and based on our legitimate interests in terms of maintaining and improving our customer service.
Your personal data related to the public campaigns and events will be processed only for the purposes of participation in the specific event organized by us and our partners, which you have attended and voluntarily participated. The legal ground for the processing of personal data is our legitimate interest to maintain an active marketing image of the complex and communication between its tenants.
Information we share
We do not disclose personal information we collect about you, we do not sell, we do not conclude commercial deals nor any other deal for transfer of your personal data to third parties.
Your personal data may be disclosed to the following persons in compliance with the principle of non-disclosure:
· Reputable professional consultants, including lawyers and other external professional consultants.
· Service providers, including companies providing products and services, such as IT service, professional property management services, and companies that we have engaged in marketing initiatives.
· State and administrative authorities, including regulators, law enforcement, public and judicial authorities.
· Companies from Sofia Airport Group in relation with their close working relations.
Data transfer
Your personal data shall not be subject to transferred to third countries outside the European Union and European Economic Area.
Our Retention of Personal Data
We process your personal data for as long as necessary for the purposes you have disclosed the data.
The general duration of personal data and document retention of clients/prospect-clients, transactions and deals is five (5) years after closing the deal and terminating the relationship with the client
If you have given consent to the processing of your personal data, Sofia Airport Center will process your personal data for the specific purpose, until you withdraw your consent.
When the need to process your personal data no longer applies and the set retention periods expire, we will erase your personal data in a secure manner.
Your rights in data processing
Upon request, you are entitled to receive free of charge information related your personal data and to access the data.
Under data protection law, you have rights we need to make you aware of. Below we have provided a list of the rights you can exercise at any time by contacting us.
• Right to access: you can ask us at any time what information we hold about you and how we process it. You can ask us for copies of your personal information. We will provide you the information free of charge unless your requests are repeating in a short period of time in which cases, we will impose a reasonable fee;
• Right to rectification: you can ask us to correct your personal data if you think it is inaccurate. You can ask us to complete your information if you think it is incomplete;
• Right to erasure: you can ask us to delete your personal data under certain circumstances, for example, if you consider that there is no good reason for us to continue to process it. Please be aware that we may refuse to delete your data if the retention periods for the respective personal data have not yet lapsed.
• Right to withdraw your consent: You may at any time withdraw your consent to process your data.
• Right to restriction of processing: You have the right to ask us to stop using your information for a period of time in certain circumstances for instance if you believe we are not doing so lawfully.
• Right not to be subject to decision based solely on automated processing: you have the right not be subject to solely automated decision making. We will always inform you if the automated decision making of your personal data leads to us reaching decisions that may affect your legal rights or have similar effect on you. In such cases you will have the right to request human interference in the decision-making process.
• Right to data portability: You have the right to ask that we transfer the information you gave us to another data controller or give it to you. The right only applies if we are processing information based on your consent or for the performance and conclusion of a contract and the processing is automated.
• Right to object: you can object to us processing your personal data if the processing forms part of our public tasks, or is in our legitimate interests, including profiling, unless we do not demonstrate overriding legitimate grounds. You can always object if the processing is for direct marketing purposes.
You can withdraw your consent for personal data processing at any time by sending an email to Nikolina Stefanova, contact details: ns@cerescee.com, tel. 02 / 492 3800.
The rights listed hereto are not absolute and there may be an exception in the cases provided by law. We will take care to give you an explanation of such exceptions when you contact us.
Sofia Airport Center does not aim to process and does not intentionally process personal data for persons under 16 years of age without the knowledge and consent of their parents or legal representatives. If you believe that we have received data from persons under the age of 16 without the knowledge and consent of their parents or legal representatives, please notify us by email: ns@cerescee.com, and we will destroy the data immediately.
Personal data protection
We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Your personal data is stored on servers of Sofia Airport Center, where they are protected by all modern and fit for the purposes standard hardware and software means of protection – fire walls, anti-virus programs, data encrypting etc. We update and test our security technology on an ongoing basis.
Sofia Airport Center ensures that access to your personal information is only granted to employees who need to process it in order to fulfil their work assignments, and that they abide by confidentiality in accordance with the applicable policies and procedures of Sofia Airport Center. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities. If you consider your rights have been violated by us during the personal data processing, you are entitled to file a complaint with Commission for Personal Data Protection, Sofia, 1592, 2 Prof. Tsvetan Lazarov Blvd., e-mail: kzld@cpdp.bg.
Links to websites
Our website contains links to other websites, e.g. social networks, business partners and advertisers. This Privacy Policy does not apply and does not apply to these other websites. In the event that you follow a link to such pages, please note that we are not responsible for the content and policies that apply to the protection of personal data on these other websites. Please check these policies before providing your personal information there.
Privacy Statement for internet
This Privacy Policy on the Internet shall be valid for personal data collected in the cases set out herein and shall not be valid for information collected in any other way.
Updates to this Privacy Policy
In case we decide to update this Privacy Policy, all changes shall be public on this website.
In case of any questions related to your personal data processing, please contact us: Sofia Airport Center EAD, a Single-Member Joint-stock Company, UIC 131006529, having its seat and address of management in Bulgaria, Sofia, 1172, 58 G.M. Dimitrov Blvd., fl. 3, Nikolina Stefanova, contact details: ns@cerescee.com, tel. 02 / 492 3800, address: Sofia, 1592, 64 Christopher Columbus Blvd.