NOTICE ON CONFIDENTIAL PROCESSING OF PERSONAL DATA

In its capacity as a personal data administrator Fairplay International AD is obliged duty to inform you what to expect when they process your personal information.

Administrator Data:

Fairplay International AD is an investment company in the real estate field. They invest in the construction and management of residential buildings and gated complexes, shopping centers and parks, logistics parks, hotels, hotel complexes and holiday villages, business buildings and agriculture.

Contact information of Fairplay International AD:

Location: Republic of Bulgaria, 1407 

City of Sofia, Lozenets district, 51B Cherni vrah blvd.;

Phone: 02/8199199; 

Email: office@fpi.bg; 

Web page: www.fpi.bg;

Fairplay International AD is a personal data administrator regarding the data of their employees and contractors. With respect to the personal data that Fairplay International AD processes for the companies controlled by them, they act in their capacity of a personal data processor. 

Contact details of the Data Protection Officer:

Phone: 02/8199309;

Email: gdpr@fpi.bg

Severina Mincheva 

 

The personal data we collect from you and process are:

Personal data category:

Any information related to an identified natural person or an identifiable natural person, namely: given names and surnames, personal number, identity document number, date and place of issue, permanent and/or current address, contact details such as telephone number, email address, Internet Protocol (IP) address; cookie ID.

Special data categories we process:

Fairplay International AD does not process special data, except employees data related to their health status concerning rights under labor insurance legislation, such as vocational rehabilitation, compensation payments, occupational medicine or social benefits such as additional health insurance. 

Source: 

We receive personal data from the data subject in person or by correspondence:

by e-mail or via the online contact form, by providing private or official documents.

We declare that the personal data we collect will only be used for the following purposes:

  • Human Resources;
  • Counterparties;
  • Video surveillance;
  • Visitors;
  • Complaints, signals, and other requests,
  • Notifications of data security breaches;

 

The basis that entitles us to process your data is: 

The processing is necessary in order to comply with our legal obligation: 

  • The Law on Obligations and Contracts,
  • Labor Code, Social Security Code and its by-laws
  • Tax and Insurance Procedural Code and VAT Law for taxation purposes (when issuing invoices)

 

Processing of your data based on the contract concluded with you.

Processing is based on:

  • the mutually reached agreement, in the event that any of the aforementioned legal grounds are not present.
  • for the exercise or defense of legal claims.
  • when entrusting the company to process personal data of a third party for the purposes of using a given service.

The processing of your data is based on your consent

  • When using social benefits such as additional health insurance.
  • For marketing and communication. To the extent permitted, we may use your personal data to provide or offer you newsletters, promotions, and current special offers, as well as other marketing communications depending on your preferences for receiving messages.

The following organizations/persons will receive your personal data:

  • public bodies – National Revenue Agency
  • insurance companies
  • company providing accounting services
  • legal consultants

Consent:

By agreeing to accept this Privacy Policy (Notice on Confidential Processing of Personal Data), you give us permission to process your personal data only for the specified purposes.

The consent is necessary for us to process both types (ordinary and special) of personal data, but it needs to be explicit. 

In cases where we ask for consent for special (sensitive) personal data, we will always justify why and how this information will be used.

You may withdraw your consent at any time via the request form.

Transfer of personal data to a country outside the EU or to an international organization

The company does not provide personal data to third parties outside the EU or to an international organization, and it does not intend to transfer your personal data to third parties without first obtaining your consent. 

Data retention period

The company stores your personal data for the following periods:

Regarding data, the processing of which is necessary for compliance with a legal obligation on our part:

  • According to the Accounting Law – 10 years, and/or until the completion of the audit and/or cross-check by the National Revenue Agency (if it has not been completed before the expiration of the 10 years).
  • In the case of employment and insurance legal relations – 50 (fifty) years.
  • In court proceedings – until the expiration of 5 years after the filing of the case in court. (pursuant to costs collection) In the case of related cases (for example, where one appears prejudicial to the other – the term expires for both cases with the expiration of the fifth year in relation to the last one in time).

Regarding data, the processing of which is necessary to comply with contractual obligations (unless the processing is on a legal basis and the law obliges us to keep your data for a longer period):

  • Until the expiration of the general five-year statute of limitations for contractual relations (according to the Law on Obligations and Contracts, with the possibility of extension after the expiration date of the above-mentioned period by the period necessary to advance the legal claim according to the Code of Civil Procedure)
  • With the expiration of the period in which claims can be made under the contract. Regarding data for the processing of which your consent is required – as long as it is necessary for the purposes for which it was given or upon withdrawal of consent.
  • Regarding video surveillance, the data are stored for a period of one month. Certain employees have access to the data within the scope of their official duties. The processing of visitors’ personal data is carried out through a security unit. The purpose of collecting personal data is to identify individuals for the purpose of access control.

 

Your data will be stored on paper and electronic media, with a developed policy and organizational security measures in accordance with the Regulation. We store your personal data for the period necessary to fulfill the purposes described in this Policy, unless a longer storage period is required or as permitted by the applicable laws. We retain other personal information for shorter periods if possible and if permitted by law.

We will destroy your personal data as soon as possible and in such a way that it cannot be reproduced or recovered. If it is printed on paper, the personal data will be destroyed in a secure way, for example by machine cutting into small parts or burning the paper documents or by other such means, and if it is in electronic form, the personal data will be destroyed by technical means so that they may not be reproduced or recovered.

 

Your rights as a personal data subject are as follows:

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

  • you have the right to request a record/copy of your personal data from Fairplay International AD and the right to access your personal data at any time;
  • you have the right to request from Fairplay International AD your personal data in a form convenient for transfer to another personal data administrator, or to request that we do so without being hindered by us;
  • you have the right to ask Fairplay International AD to correct inaccurate personal data, as well as data that is no longer up-to-date;
  • you have the right to ask Fairplay International AD to delete your personal data if there is any of the following reasons:
    • the personal data are no longer necessary for the purposes for which they were collected;
    • when you have withdrawn your consent; o when you have objected to the processing, o         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 law of a Member State that applies to us as a personal data administrator; We may refuse to delete your personal data for the following reasons:
    • to exercise the right to freedom of expression and the right to information;
    • to comply with a legal obligation on our part o for reasons of public interest; 
    • for the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes, to the extent that deletion is likely to make impossible or seriously hinder the achievement of the purposes of this processing; or for the establishment, exercise or defense of legal claims. o for the establishment, exercise or defense of legal claims

 

  • you have the right to ask Fairplay International AD to limit the processing of your personal data, in which case the data will only be stored, but not processed. Our refusal to limitation will be explicit only in writing, and we are obliged to motivate it with the legal reason;
  • you have the right to withdraw your consent to the processing of your personal data at any time with a separate request addressed to the administrator;
  • you have the right to object to certain types of processing, such as direct marketing (unsolicited advertising messages);
  • you have the right to object to automated processing;
  • you have the right not to be subject to a decision based solely on automated processing involving profiling;
  • if we need to use your personal data for a new purpose that is not covered by this data protection declaration, we will provide you with a new data protection notice and, when and where necessary, we will request your prior consent for the new processing.

All of the above requests will be forwarded if there is a third party (recipients including non-EU and international organizations) processing your personal data.

Information and requests are processed free of charge, except in cases regulated by law, where the administrator has the right to set a reasonable fee.

In order to gain access to your data, which we process, it is necessary to make a request for access to the indicated contact details of Fairplay International AD or directly to the person responsible for data protection. In order to verify your identity, it is necessary to provide sufficient data in order to conduct a reliable check in our databases so that we can answer your access request correctly and in a timely manner.

 

You have the right to appeal to the supervisory authority

You have the right to file a complaint directly with the supervisory authority, the competent authority being the Personal Data Protection Commission.

In the event that you wish to file a complaint regarding the processing of your personal data by the company, you may do so at the specified contact details of the company or directly to the person responsible for data protection at the contact details specified above.

 

Privacy Policy Changes 

We reserve the right to change our privacy policy. 

If you have any questions regarding the processing of your personal data, please contact us using the indicated contact forms.