PERSONAL DATA PROTECTION POLICY OF KALINA TRAVEL OOD, UIC 131010207
- “Personal data” shall mean any information relating to an identified or identifiable natural person (“DATA SUBJECT”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online id or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a said natural person.
- “Processing personal data” shall mean any operation or set of services which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- 3. “Personal Data Protection Policy” (hereinafter referred to as the „Policy”) for the purposes of this document shall mean the policy for the protection of personal data in compliance with 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 such data (hereinafter referred to as the “Regulation”) and it shall be applied by Kalina Travel OOD.
- “Filing system” shall mean any structured set of personal data which is accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
- “Recipient” shall mean a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry following Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing;
- “Controller” shall mean the natural or legal person, public authority, agency or another body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where Union or Member State law determines the purposes and means of such processing, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
- “Online platform” – a unified virtual environment for the purchase of plane tickets, insurance, trips and vacations, transport services (transfers) in real-time, as well as for renting vehicles for temporary use, which can only be accessed by registered users.
- “Registered users of the online platform” shall be both the suppliers of the following services, namely: place tickets, insurance, trips and vacations, transport services transfers), the provision of vehicles for temporary use; and the potential buyers of those services, namely: travel agencies, tour operators and corporate clients who have registered for the purpose of the online platform.
- “Contact persons“ – a natural person stated by a registered user of the online platform that the platform’s controller and the other registered users can contact.
- “Responsible persons” – a natural person stated by a registered user of the online platform who implements management functions within the latter.
- “Company employees” – natural persons employed at Kalina Travel who have concluded an employment or civil contract with the said Company
- INFORMATION about Kalina Travel OOD
- Kalina Travel OOD, UIC 131010207, with a seat and registered office in Sofia, Vitosha Region, 4 Gergyovche Str. (from now on referred to as “Kalina Travel” the “Company”), is a company registered in the Republic of Bulgaria which is a controller and recipient of personal data and is represented by its Managers Lyubomir Georgiev Velkov and Kalina Valentinova Velkova.
- Kalina Travel processes the personal data it has been provided with lawfully, in goodwill and with transparency with regard to the Data Subject, in compliance with the principles and requirements of 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 such data (hereinafter referred to as the “Regulation”).
III. CATEGORIES OF PERSONAL DATA
- Kalina Travel processes a minimum quantity of “regular” personal data of the natural persons – the contact persons and the financially liable person stated by the users of the website, namely: name and surname.
- Kalina Travel processes the following “regular” personal data of the natural persons: whether they are employed through an employment or civil contract by Kalina Travel, namely: full name, Personal No, date of birth, address, ID card No.
- Kalina Travel also processes data such as the office address, office phone number, office email address of the contact persons and the financially liable person; the name of travel agencies, tour operators, commercial companies, hotels, their registration/license numbers, seats, and management addresses, as well as their email addresses.
- Kalina Travel does not process personal data revealing racial or ethnic origins, political opinions, religious or philosophical beliefs, or trade union membership, nor genetic data, biometric data to uniquely identify a natural person, medical data or data concerning a natural person's sex life or sexual orientation.
- PURPOSES OF THE PROCESSING OF PERSONAL DATA
- Depending on the personal data subject, Kalina Travel processes the following data for the following purposes:
1.1. The data of contact persons and financially liable persons are prepared for the following purposes:
- Informing the platform users of current offers provided by the platform,
- removing problems and ambiguities which may have occurred during the use of the platform,
- responding to questions and requests put forward by the respective platform user,
- the performance of the contracts concluded between Kalina Travel and the platform users.
1.2. in addition to the purposes under the previous item, the data of the contact persons are also processed for direct marketing, insofar as the contact person is receiving a newsletter containing the current offers of Kalina Travel on behalf of the entity they are representing.
1.3. The data of the company’s employees are processing for compliance with the statutory obligations of the Company as an employer and contracting party under civil contracts, respectively.
- V. PROCESSING PERIOD
- The processing period for the personal data of contact persons and liable persons
Kalina Travel only processes the personal data of the contact persons and the financially responsible persons for a period starting with the submission of the registration form of the platform user featuring a contact person and a financially responsible person and ending on the date of erasure/change of the contact person/financially accountable person at the request of the respective platform user.
- The processing period for the personal data of workers/employees
2.1. Kalina Travel processes the personal data of their employees as per its statutory obligations for the development and storage of a work file for each worker/employee, containing all documents related to the occurrence, modification, and termination of the employment relationship.
2.2. After the completion of the employment relationship, Kalina Travel continues to store the documents from the work file for three years, except payroll documents.
2.3. Payroll documents are stored for 50 years following the procedure provided in the State Archival Collections Act.
2.4. Materials which are not subject to entry into the Archives State Agency are destroyed after the end of their storage period.
- PROCESSING METHOD
- Kalina Travel stores the documents containing personal data by technical (electronic) means and on paper.
- Kalina Travel maintains a register, wherein the following information is documented: name of the legal entity (hereinafter referred to as “LE”) – platform user, unified identification code of the LE, name and surname of the financially liable person, address of the LE, “industry”, “abbreviation”, VAT number, license number, name and surname of the natural contact person, office phone number of the contact person, office address of the contact person, office email of the contact person.
- The online register contains the minimum quantity of personal data, specifically – name and surname of the financially liable person and the contact person.
VII. PROCESSING GROUNDS
- Kalina Travel processes the data of the contact persons and the financially liable persons – employees/representatives of the travel agencies, tour operators, commercial companies/hotels and other legal entities, for the purposes of protecting the legitimate interests of Kalina Travel with regard to the performance of the contracts concluded between Kalina Travel and the relevant travel agency/tour operator/hotel or other legal entity.
- Kalina Travel processes the date of its employees on the grounds of the employment or civil contracts if they have entered into.
VIII. ACCESS TO PERSONAL DATA
- Access to the personal data of the contact persons and the financially liable person is provided to the employees of Kalina Travel in compliance with all protection and privacy policies, to the IT company responsible for the maintenance of the online platform and to third parties, as provided by law.
- The personal data of the employees of Kalina Travel employed through employment/civil contracts can be disclosed to the following third parties – entities: the accounting company responsible for the bookkeeping of Kalina Travel for the purposes of accounting activities, to the competent state authorities in the cases provided for in Bulgarian legislation and in the laws of the European Union.
- Rights of the PERSONAL DATA SUBJECTS
- The personal data subject shall have the right to obtain confirmation from Kalina Travel as to whether or not personal data concerning them are being processed, and, where that is the case, to receive access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data being processed;
- the recipients to whom the data will be disclosed;
- the storage period or the criteria for its length;
- the right to request rectification;
- the right to request the erasure of the personal data;
- the right to request the restriction of processing for their data;
- the right to data portability;
- the right to object against such processing;
- the right to complain about a supervisory authority;
- the person was providing the data (this shall only apply to the contact persons stated by the registered users of the website).
- RIGHT TO RECTIFICATION
The personal data subject shall be entitled to requesting the rectification of their data from Kalina Travel, as well as the supplementation of incomplete personal data.
- RIGHT TO ERASURE
3.1. The personal data subject shall be entitled to requesting the erasure of their data from Kalina Travel.
3.2. Kalina Travel shall erase the subject's data at their request in the following cases:
- where the personal data is no longer necessary concerning the purposes for which they were collected or otherwise processed;
- where the data subject withdraws their consent and where the grounds for data processing are solely consenting, and there are no other grounds for their processing;
- where the personal data have been processed unlawfully;
- where the personal data has to be erased for compliance with a legal obligation in Union or Member State legislation to which the controller is subject;
3.3. Where the issue has requested erasure, Kalina Travel shall take all necessary steps to the inform controllers processing the personal data that the data subject has asked for the erasure from such controllers of any links to or copies/replications of the personal data.
3.4. The issue has the right to refuse any further informational emails through automatic unsubscribing (URL) every time they receive an email from Kalina Travel.
- RIGHT TO THE RESTRICTION OF PROCESSING
4.1. The data subject shall have the right to request the restriction of processing from Kalina Travel, where one of the following applies:
- a) the accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data;
- b) the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- c) Kalina Travel no longer requires the personal data for the purposes of the processing; however, they are required by the data subject for the establishment, exercise or defence of legal claims;
- d) the data subject has objected to the processing according to Article 21(1) of the Regulation pending verification of whether the legitimate grounds of the controller override those of the data subject.
4.2. Where processing has been restricted, personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or of a Member State.
4.3. Kalina Travel shall inform the subject requesting the restriction before the suspension of said restriction of the processing.
- RIGHT TO DATA PORTABILITY
5.1. The data subject shall have the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and they shall have the right to transmit said data to another controller without hindrance from the controller to which the personal data has been provided, where:
- The processing is based on consent or a contractual obligation, and
- the processing is performed in an automated manner.
5.2. In exercising his or her right to data portability, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
- RIGHT TO OBJECT TO THE PROCESSING
6.1. Where Kalina Travel processes personal data according to Article 6, Paragraph 1, b. e), namely: for their legitimate interests or that of a third party, the data subject shall have the right to object to the processing of their data.
6.2. In such cases, Kalina Travel shall suspend the processing of personal data, unless they can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
- EXERCISING YOUR RIGHTS
- The personal data subject shall direct their requests, inquiries, and objections to Kalina Travel at the following email address: email@example.com
- The requests/inquiries/objections of the data subject can be sent in writing to Kalina Travel at the given mailing address: Sofia, Vitosha Region, 4 Gergyovche Str.
- The requests/inquiries/objections of the data subject can also be sent electronically to firstname.lastname@example.org
- The requests/inquiries/objections shall be submitted personally by the natural person or by a person explicitly authorised by them through a notarized Letter of Attorney.
- The requests/inquiries/objections shall include the name, address and other identifiable data of the respective natural person; a description of the request; the preferred method of delivery of the information – in writing, verbally, electronically; a signature, the submission date of the application and a mailing address/email.
- Where an authorised person files a request, a notarized Letter of Attorney shall be attached to the application.
- Kalina Travel shall make a statement with regard to the requests, inquiries, and objections of the personal data subjects within 1 (one) month as of the reception of the application and they shall inform the issue as to the result within the same period by sending a message to the email address stated by the data subject.
- Kalina Travel shall provide the information requested by the data subject in writing, verbally or electronically with an email message, depending on the method stated by the data subject.
- Kalina Travel shall communicate any performed rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data has been disclosed unless this proves impossible or involves a disproportionate effort. Kalina Travel shall inform the data subject regarding those recipients if the data subject requests it.
- Kalina Travel shall provide the requested information to the data subject free of charge.
- Kalina Travel shall be entitled to request that the data subject pays a fee or to refuse to act on the request, where the demands of the data subject are unfounded or excessive due to their repetitive nature.
- Where Kalina Travel has reasonable doubts concerning the identity of the natural person making the request, they can request the provision of additional information necessary to confirm the status of the data subject.
- Kalina Travel keeps a dedicated register for requests/inquiries/objections which includes brief entries regarding the contents of the request/inquiry/objection, which the data subject sending it is/ the date on which the request/inquiry/objection was received, the time on which Kalina made a statement Travel with regard to the latter, as well as a brief overview of the content of the said statement.
- The website of Kalina Travel – www.kalinatravel.eu may contain links to websites which are the property of third parties. Such sites have their personal data protection policies, and Kalina Travel advises the data subjects to review them. Kalina Travel is not liable concerning the individual data protection policies of such websites, and the use of such sites shall be performed at the data subject’s own risk.
- Kalina Travel does an annual review on the need for personal data processing, respectively on the necessity for the erasure of such data.
- Users can contact Kalina Travel at the following email address: email@example.com
- Final provisions
Any issues not settled by this Policy shall be governed by the requirements of the Regulation and the Bulgarian legislation.