General data protection regulation
Personal data protection policy of IV Group Ltd.
for the Camper Pro Rent service
I V Group Ltd. (the Controller) is a company entered into the Trade Register and the Register of non-profit legal entities with the Registry Agency, UIC 175191595; headquarters and business seat: Republic of Bulgaria, Sofia, N 6, Okolchitsa Str. entr. B, fl. 7.
I V Group Ltd. contact information in view of protection of the personal data of our clients
IV Group Ltd.
City of Sofia, N 6, Okolchitsa Str. entr. B, fl. 7
Personal data protection officer - Vyara Dimitrova Ilieva
The protection of personal data of each client is of significant importance for I V Group Ltd. Private data protection policy stipulates how we process your data and what are the measures undertaken by us to protect them; where and how we collect your personal data as well as what are your rights in view of the information saved about you.
I V Group Ltd. collects and processes personal data only in compliance with the requirements of the Personal Data Protection Law, Regulation 2016/679 on the protection of data of natural persons with regard to the processing of personal data, Ordinance N1 dated 30 January 2013 on the minimal level of the technical and organizational measures and permissible personal data protection. Always, the processing of your personal data depends on certain reason and it could not be made without any restrictions.
For the purposes of the present Policies and in compliance with the stipulations in Article 4 of Regulation (ЕU) 2016/679 of the European Parliament and of the Council since 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation):
‘personal data’ means 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 identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
How and why do we use your personal data?
For execution of a contract or in view of the pre-contractual conditions
I V Group Ltd. processes your identification data and some other personal data in order to provide you with our products and services upon your request as used by you according to contracts concluded with us. Also, we process your personal data in order to fulfill our contractual and pre-contractual obligations as well as to use the rights under the contracts concluded with you.
The processing is made for the purposes of:
- identification of your identity as a client;
- management and execution of the contracts concluded for products and services;
- elaboration of offers for conclusion of a Contract;
- for preparation and provision of a pre-contractual information;
- preparation and sending of an invoice for the products and/or services used;
- provision of the whole services needed for you as well as for collection of the amounts due for the used products and services;
- sending of courier services with a notification letters, service of cancellations of a deal, complaints etc.;
- notification about everything related to the products and services provided by us, sending of different notices, notifications about problems, errors or for answering to your requests, complaints and proposals;
- Establishment and/or prevention of illegal actions or actions in contradiction to the our conditions for the respective services;
For execution of the regulatory obligations
We process your personal data in order to observe the obligations foreseen in a regulation e.g.:
- provision of information to the commission for protection of the personal data in connection with the obligations stipulated in the regulations for protection of the personal data, Regulation (EU) 2016/679 dated 27 April 2016 year etc.;
- provision of information to the Commission for protection of the consumers or third parties stipulated in the Law for protection of the consumers;
- obligations, stipulated in the Accountancy Law and in the Tax and Insurance Procedure code as well as in some other regulations related to the keeping of correct and legal accountancy.
- Provision of information to the state authorities, stipulated in the Law against Money Laundry;
- Provision of information before the authorities of the Ministry of Interior related to our obligation stipulated in the Traffic Act;
- Provision of information to the court and third persons within the court procedure in compliance with the requirements of the procedure and substantive legal acts applicable to the procedure;
Upon your agreement:
In some cases, we process your personal data only upon your written agreement. The agreement is different grounds for processing of your personal data, the purpose of processing is stipulated in it and it does not coincide with the purposes stipulated in this policy. If you give us the respective agreement and until its cancellation or termination of any contractual relationships with you:
- We shall send you some ongoing advertising campaign, news and offers, information on forthcoming service campaigns as well as we shall send you some marketing notifications.
- Agreements provided by you could be canceled any time. The cancellation of the agreement does not affect the execution of the contractual obligations of I V Group Ltd.
Type of data processed by us:
- Full name, personal identification number or personal number of foreigner, permanent address; driving licence data;
your contact details:
- e-mail Phone
- Information on the type and content of the contractual relationships as well as any other information related to the contractual relationships, including:
- e-mail, letters, information on your requests for solution of problems, complaints, requests, claims;
- Information on the number of bank account and other bank and payment information related to the payments made to I V Group Ltd.
- other information such as:
- data sent via company web page;
- information on the used end electronic communication device, type of the device, used operational system, IP addresses from a visit of our web page;
When we process your personal data and the other data specified for the purposes of supply of products and services, for their payment, for execution of your requests for services as well as in order to fulfill our regulatory obligations, this processing is mandatory for the execution of these purposes. Without these data, we are not able to provide you the respective services. If you will not provide us any identification data, we shall not be able to conclude a contract with you about a product or service.
How do we protect your personal data?
We treat your data as strictly confidential. For their protection we have undertaken a lot of protection measures including administrative, technical and physical measures stipulated in the Law for protection of the personal data and Ordinance N1 dated 30 January 2013 1 on the minimum level of technical and organizational measures and permissible type for protection of the personal data.
When do we delete your personal data?
As a rule, we terminate the use of your personal data for the purposes related to the contractual relationships, after the termination of the contract. However, we do not delete them before the final settlement of all financial obligations and/or expiration of the legal established obligations for saving of the data such as obligations according to the Accountancy Law for saving and processing of accountancy data (11 years); expiration of the limitation periods for provision of information to the court, competent state authorities and some other grounds stipulated in the effective legislation (10 years). Please, take into account that we shall not delete or make anonymous your personal data if they will be required for a pending suit, administrative procedure or processing of your complaint to us.
When and why do we share personal data with third persons?
We provide your personal data to third persons and our main objective is to offer you fast, qualitative and complex service as taking care for the services and products offered by us to meet your expectations. We do not provide personal data to any third persons before being sure that all technical and organizational measures for protection of these data are undertaken endeavouring to execute strict control over the execution of this objective. In this case, we remain responsible for the confidentiality and reliability of your data.
We provide personal data to the following categories of recipients:
- Persons nominated to maintain equipment, software and hardware used for processing of personal data and needed for construction of the company network and for execution of different services for reporting, payment of services and products, technical support etc.;
- post operators and courier companies in view of sending of parcels containing contracts, annexes and other documents as well as regarding identification of the identity upon their delivery;
- officers of the company for processing of the contractual relationships;
- banks and bank institutions related to the payment processing;
- persons providing service maintenance of the vehicles rented by your under a long-term contract; during the duration of the contractual relationships;
- competent authorities, which pursuant to a regulation are authorized to require provision of information, including personal data e.g. courts, prosecutor’s office, different regulatory authorities such as Customers Protection Commission, Commission for protection of the personal data, state authorities with powers for protection of the national security and public order;
I V Group Ltd. does not provide your personal data to third persons staying in any countries beyond EU.
Your rules related to the processing of your personal data
You have the right to request:
- information whether the data related to you are processed, information on the purposes of this processing, on the category of data and recipients or categories of recipients to whom the data are disclosed;
Right of restriction of the processing:
You might require restriction of the processed personal data, if:
- you contest the correctness of the data for the period when we have to verify their correctness;
- processing of the data is without any legal grounds, but instead of deleting them you require their restricted processing; or
- we do not need these data anymore for the processing purposes, but you need them for the establishment, execution or protection of legal claims; or
- you have contested the processing of the data expecting verification whether the justifications of the controller are legal.
Right of correction:
In case we process non-completed or false data, you have the right to request any time:
- deletion, correction or blocking of your personal data, which processing does not comply with the legal requirements;
- To notify the third persons before whom your personal data have been disclosed about any deletion, correction or blocking except the cases when this is not possible or is related to enormous efforts.
Rights of data portability:
You could ask us to provide the personal data transferred to us in an organized, ordered, structured, common electronic format, if:
- we process the data either according to the contract and the declaration of consent, which could be revoked or pursuant to a contractual obligation and
- the processing will be made automatically.
The right of deletion (right to be forgotten)
- You have the right to ask us to delete your personal data and we are obliged to delete them without any unreasonable delay in case of any of the grounds specified here below:
- Your personal data are not needed anymore for the purposes they have been collected or processed in any other manner;
- You have canceled your consent, which have been grounds for the processing of your personal data;
- Your object the processing of your personal data and we do not have any prevailing legal grounds for their processing or you are against the processing of your personal data for a direct marketing;
- Your personal data have been processed illegally;
Right of objection:
Any time you have the right to:
- object the processing of your personal data if some respective legal grounds are available; when the objection is reasonable the personal data of the respective natural person could not be processed any more;
- object the processing of your personal data for the objectives of the direct marketing.
Right of complaint:
If you think that we violate the applicable regulations, please contact us for clarification of the issue. Certainly, you have the right to appeal against the Commission for protection of the personal data or before a regulatory body within the EU.
The applications for access to information or for correction are sent personally or by a person explicitly authorized by you on the grounds of notary certified power of attorney. The application could be sent via electronic way pursuant to the order of the Law for electronic document and electronic signature.
We shall answer your request within 30-day term. With our decision, we shall provide or reject the access and/or the information required by the applicant and our answer will be always justified.
Updates and amendments of the policy
In order to apply the most updated measures for protection as well as to comply with the effective legislation, we shall update regularly the resent policy for protection of the personal data. If the amendments made by us are considerable, we might publish on our website an announcement about the changes made. We would like to ask you to review the current version of this Policy for protection of the personal data in order to be continuously aware about our care for protection of the personal data protected by us.
The last update of this policy for protection of the personal data is made on 13 May 2019.