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Privacy Policy

Mandatory information on the rights of individuals with regard to personal data protection (Privacy Notice)

The General Data Protection Regulation or GDPR, adopted by the European Union, entered into effect on 25 May 2018. This Regulation is intended to ensure the protection of data of all natural persons living within the EU and to synchronize the regulations governing data processing.

As a personal data controller for the purposes of providing advertising services, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD (The Company) complies with all of the requirements set by the GDPR, collecting and processing personal data only to the extent necessary for the provision of the service, and protecting the data by applying responsible and lawful data practices.

Information about the Controller

  1. Name: RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD
  2. Unified Identification Code (UIC): 203091110
  3. VAT Number: BG203091110
  4. City: Sofia
  5. Address: 3A Moskovska Street, floor 5
  6. E-mail: info@re-invest.bg
  7. Telephone number: +359 2 950 53 34

Information about the competent Supervisory Authority

  1. Name: Commission for Personal Data Protection
  2. Seat and registered office: city of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
  3. Correspondence address: city of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
  4. Telephone number: +359 2 915 3 518
  5. E-mail: kzld@government.bg, kzld@cpdp.bg
  6. Website: www.cpdp.bg

RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD conducts its activities in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 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.

Grounds for collecting, processing and storing your personal data

Art. 1. (1) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD collects and processes your personal data in connection with the Company's business activities on the following grounds:

  1. explicit consent provided by you as a customer;
  2. fulfilment of the obligations which RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD has under the contract with you;
  3. compliance with the legal obligation to which RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD is subject;
  4. for the legitimate interests pursued by RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD.

(2) With regard to your data as the User of our services, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD acts as a controller. With regard to the personal data that you process using our services, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD acts as a processor.

Purposes and principles for collecting, processing and storing your personal data

Art. 2. (1) RESOLUTE ASSET MANAGEMENT (BULGARIA) collects and processes the personal data which you provide to us in connection with the use of our advertising services and products as well as the data you provide when you enter into a contract with the Company, including for the following purposes:

  1. Accounting purposes;
  2. Statistical purposes;
  3. Information security;
  4. Securing the implementation of a contract for the provision of a service;
  5. Sending communication notices, announcements about changes in the service, and notices about newly opened sites;
  6. Sending personalized notices about tailored offers based on your previous contact.

(2) When processing your personal data, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD complies with the following principles:

  1. Lawfulness, fairness and transparency;
  2. Purpose limitation;
  3. Adequacy for the purposes and data collection minimization;
  4. Accuracy and timeliness of the data;
  5. Storage limitation solely for the purposes;
  6. Integrity and confidentiality of the processing and ensuring an adequate level of data security.

(3) When processing and storing personal data, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD may process and store personal data needed in order to protect the following legitimate interests of the Company:

  1. Compliance with the obligations that the Company has to the National Revenue Agency, the Ministry of Interior and other governmental or municipal authorities.

What types of personal data does RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD collect, process and store?

Art. 3. (1) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD performs the following operations with your personal data for the following purposes:

  1. Sending information messages - the purpose of this activity is to administer the process of sending you messages that relate to the opinion or inquiry you have requested from us;
  2. Sending a newsletter - the purpose of this operation is to administer the process of sending newsletters to users who have stated that they wish to receive newsletters.

(2) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD processes the following categories of personal data and information for the following purposes and on the following grounds:

  1. Data: Your identifying data (name and surname, email, phone)
    1. Purpose for which the data are collected: 1) Establishing contact with the users and sending information to the users, including (if subscribed) sending newsletters and advertising messages;
    2. Grounds for processing your personal data – By ordering the service / product from RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD you enter into a contract based on which we will process your personal data - Art. 6, Para. 1, Item (b) of the GDPR.
  2. Other data that RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD processes – When visiting our website, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD collects data about the IP address from which you connect.
  3. Personal data that are needed for the issuance of an invoice to a natural person – If you want an invoice to be issued to you as a natural person, you should provide us with your personal identification number.
    1. Purpose for which the data are collected: Issuance of an invoice for payment for the provision of services.
    2. Grounds for processing your personal data – By ordering the service from RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD you enter into a contract based on which we will process your personal data - Art. 6, Para. 1, Item (b) of the GDPR.

(3) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD does not collect or process personal data that relate to the following:

  1. Data that reveal your racial or ethnic origin;
  2. Data that reveal your political, religious or philosophical beliefs, or trade union memberships;
  3. Genetic or biometric data, data related to your health, sexual life or sexual orientation.

(4) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD collects personal data from the persons to whom the data relate.

(5) The Company does not use the collected data for automated decision-making purposes.

Storage period of your personal data

Art. 4. (1) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD stores your personal data only for the period that is necessary to implement our contract. Upon the expiry of this period, RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD will take reasonable care to erase and destroy all of your data without undue delay.

(2) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD will notify you in case the storage period needs to be extended in order to achieve the purposes, to implement the contract or for any other reasons related to the legitimate interests of RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD, etc.

(3) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD keeps the personal data that it is required to keep under the applicable law for the required period which may exceed the period of the contract between the parties.

Transfer of your personal data for processing

Art. 5. (1) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD may, at its sole discretion, transfer all or part of your personal data to personal data processors for the fulfilment of the processing purposes, subject to the requirements of Regulation (EU) 2016/679.

(2) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD will notify you in case it intends to transfer all or part of your personal data to third countries or to international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawal of consent to process your personal data

Art. 6. (1) If you no longer wish all or part of your personal data to continue to be processed by RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD for a specific purpose or any processing purpose, you may, at any time, withdraw your consent to process your personal data by sending a free text request.

(2) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD may require you to prove that your identity matches the identity of the data subject.

(3) By withdrawing your consent for the processing of your personal data necessary for the performance of the requested service / product, you give RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD the right to refuse to perform the service.

Right of access

Art. 7. (1) You have the right to request and receive from RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD a confirmation as to whether personal data related to you are being processed.

(2) You have the right of access to all of the data that relate to you as well as all of the information that relates to the collection, processing and storage of your personal data.

(3) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD will provide you, upon request, a copy of the processed personal data that relate to you, in an electronic or another appropriate form.

(4) Access to the data is free of charge, but RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD reserves the right to impose an administrative fee in the event of recurrence or an inappropriate number of requests.

Right to have the data rectified or completed

Art. 8. You can correct or complete the inaccurate or incomplete personal data that relate to you by sending a free text request to RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD.

Right to erasure (right to be forgotten)

Art. 9. (1) You have the right to request from RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD the erasure of your personal data, and RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD has the obligation to erase the data without undue delay where one of the following grounds applies:

  1. Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. You have withdrawn your consent on which the processing was based, and there is no other legal ground for the data processing to continue;
  3. You have objected to the processing of our personal data, including for the purposes of direct marketing, and there are no other overriding legal grounds for the data processing to continue;
  4. Your data have been processed unlawfully;
  5. Your personal data have to be erased for compliance with a legal obligation in the European Union or with Member State law to which RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD is subject.

(2) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD is not obligated to erase your personal data if the data are stored and processed for the following:

  1. Exercising the right of freedom of expression and information;
  2. Compliance with a legal obligation that requires processing according to the Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
  3. Reasons of public interest in the area of public health;
  4. Archiving in the public interest, scientific or historical research or statistical purposes;
  5. Establishment, exercise or defence of legal claims.

(3) In order to execute your right to be “forgotten”, you should submit a written request to RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD and prove that your identity matches the identity of the person to whom the data provided to RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD relate.

(4) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD does not erase data that it has a legal obligation to store, including for protection against legal claims brought against it or data needed to prove its rights.

Right to restriction of processing

Art. 10. You have the right to obtain from RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD restriction of processing of the data that relate to you where one of the following applies:

  1. You contest the accuracy of the personal data, for a period enabling RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD to verify the accuracy of the personal data;
  2. The processing is unlawful, but you oppose the erasure of the personal data and only request the restriction of their use;
  3. RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defence of legal claims.

Right to data portability

Art. 11. (1) You may, at any time, by an email request, withdraw the data about you that are stored and processed in relation to your use of services provided by RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD.

(2) When it is technically feasible, you may ask RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD to transfer your personal data directly to another controller of your choice.

Right to receive information

Art. 12. You may request from RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD to inform you of all recipients that have received personal data for which rectification, erasure or restriction of processing has been requested. RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD may refuse to provide this information if this would not be possible or would require a disproportionate effort.

Right to object

Art. 13. You may, at any time, object to the processing of your personal data by RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD, including if the data are processed for the purposes of profiling or direct marketing.

Your rights in the event of a personal data breach

Art. 14. (1) If RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD becomes aware of a personal data security breach that is likely to result in a high risk to your rights and freedoms, we will, without undue delay, notify you about this breach and will inform you about the measures that we have taken or we are about to take.

(2) RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD is not obligated to notify you if:

  1. RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD has implemented appropriate technical and organizational measures for protection of the data affected by the security breach;
  2. RESOLUTE ASSET MANAGEMENT (BULGARIA) EOOD has taken subsequent measures which ensure that the high risk to your rights and freedoms is no longer likely to materialize;
  3. The notification would involve a disproportionate effort.

Other provisions

Art. 15. In the event of a violation of the rights you have under the above-mentioned or under the applicable data protection legislation, you have the right to file a complaint with the Commission for Personal Data Protection as follows:

  1. Name: Commission for Personal Data Protection
  2. Seat and registered office: city of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
  3. Correspondence address: city of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
  4. Telephone number: +359 2 915 3 518
  5. E-mail: kzld@government.bg, kzld@cpdp.bg
  6. Website: www.cpdp.bg

Art. 16. You may exercise all of your rights related to the protection of your personal data by using the appropriate standard forms attached to this information. Of course, these standard forms are not mandatory and you may submit your claims in any form that contains a statement about the matter and identifies you as the data holder.

Art. 17. If the consent relates to a transfer, the Controller shall inform the data subject about the possible risks of such data transfer to third countries due to the absence of adequate protection and appropriate remedy.

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