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PRIVACY POLICY

 

Last updated on 04.04.2019.

We “TRAMPOLINE PARKS AREA 52” AD (“we” or the “Controller”) in some individual cases collect and process personal data of natural persons, our clients, counter parties, representatives or employees of the latter, or other contacts on the Bulgarian market (“You”). We are aware of the responsibility we have to take care and protect your personal data, to observe the applicable law in regard with personal data privacy and protection.

With this Privacy policy (“the Policy”), we would like to provide you with information on the way we collect and process the personal data you have submitted to us. The policy describes the methods used herein and the purposes applied by “TRAMPOLINE PARKS AREA 52” AD our service providers in relation to the processing of the information respectively collected from and for you regarding entering into contractual relations or usage of our services on site in our commercial zone and/or through our website http://www.area52.bg/ („the Website“).

Important!

Please read carefully this Policy. Herein is presented important information regarding the way we process Your Personal data and it provides explanation for your legitimate rights. This policy is not aiming to amend any terms under any contract with us as a counterparty, neither your rights, nor our obligations according to the applicable law for personal data protection.
By providing your personal data or using the Website, you voluntarily consent to the terms herein.

1. CONTROLLER

1) Personal data Controller is “TRAMPOLINE PARKS AREA 52” AD with the following details:

„TRAMPOLINE PARK AREA 52“ AD, UIC 204748721, Website: www.area52.bg

Registered management addressCommercial zone („The Park”)Single point of contact with the Controller regarding all types of issues, concerning personal data:
Sofia 1408,
139 „Vitosha“ Blvd., entr. А, app.13
tel.: +359 883 905 252;
email: manager@area52.bg		Sofia 1434,
214 „Okolovrasten pat“ Blvd., Sofia Ring Mall, premise № 0.27
tel.: +359 883 905 252;
email: reception@area52.bg;		Radostina Elias, Manager
Address: Sofia 1434, 214 „Okolovrasten pat“ Blvd., Sofia Ring Mall, premise № 0.27
tel.: +359 883 905 252
email: gdpr@area52.bg

2) „TRAMPOLINE PARKS AREA 52” AD as personal data Controller is responsible for the proper and legitimate processing of the personal data provided when entering into contractual relation or using the services through our Website or other services provided by us.

2. HOW DO WE COLLECT YOUR PERSONAL DATA 1. HOW DO WE COLLECT YOUR PERSONAL DATA 

„TRAMPOLINE PARKS AREA 52” AD can collect and process your personal data in the following cases:

  • If you or your child attend our Park on site and provide your or your child’s personal data through filling a Declaration of consent;
  • If you make a booking for the Park on our Website and provide your personal data / your child’s personal data through filling a booking form and a Declaration of consent;
  • If you provide your personal data upon signing a contract with “TRAMPOLINE PARKS AREA 52” AD;
  • If you are purchasing a product or service directly from us or through our Website;
  • If you answer to our direct marketing campaigns, for instance through filling a questionnaire or if you enter data online on the Website;
  • If any third parties (our business partners) execute permitted transfer of your personal data to us.

In case you provide information on behalf of other person, you should make sure that this person is aware of the current Policy and that the provisions of the applicable law are adhered to before you provide the information.

If your age is under 14 years, please do not submit us your data, unless you have permission by a family member to do so.

We would like to ask you for your assistance which consists of informing us for any changes in your personal data, in order to maintain your information up to date.

3. WHAT KIND OF PERSONAL DATA DO WE COLLECT 1. WHAT KIND OF PERSONAL DATA DO WE COLLECT 

The following categories personal data could be collected from and for you based on whether you are our client, counterparty and which of our services you use:

  • Regarding the physical identity – names (name, given name and surname), date of birth, telephone, e-mail address;
  • Regarding economical identity – bank account;
  • Interests – the information provided in regard with your personal interests;
  • Image (our Park is under video surveillance)

4. HOW COULD YOUR PERSONAL DATA BE PROCESSED 1. HOW COULD YOUR PERSONAL DATA BE PROCESSED 

The processing of personal data according to the applicable Bulgarian law and the Framework Directive’s principles of the European Union for data protection and in particular of the General Data Protection Regulation EU/2016/679 (“the Regulation”) shall be justified according to one of several legal grounds and we are requested to specify the purposes and grounds for each usage of your Personal data.

1) Purpose: Exercising the rights and obligations of the Controller arising in regard to signed with you contracts, in this regard for the usage of our services;

Ground for processing: execution of a contract or compliance with legal obligation (art. 6, para. 1, letter “b” or letter “c” of the Regulation);

2) Purpose: Execution of an accounting/ financial activity by the Controller upon and in regard with the signed contracts, in this regard: receiving and transfer of due payments under bank accounts; receiving/issuance of invoices;

Ground for processing: execution of a contract or compliance with legal obligation (art. 6, para. 1, letter “b” or letter “c” of the Regulation);

3) Purpose: Correspondence with clients of the Controller and providing client’s service, in this regard in order to answer your questions and execute your requests, for instance in order to send you the requested documents or notifications by email; to send you important information concerning our relations or in regard with amendments in our internal terms and conditions, and policies;

Ground for processing: execution of a contract or compliance with legal obligation (art. 6, para. 1, letter “b” or letter “c” of the Regulation); or an expressly given consent by each entity (art. 6, para. 1, letter “b” or letter “c” of the Regulation) or on the ground of the legitimate interests of the Controller (art. 6, para. 1, letter “b” or letter “c” of the Regulation);

4) Purpose: Direct marketing

Ground for processing: expressly given consent of each entity according to the provisions of art. 6, para. 1 a from the Regulation;

5) Purpose: For business related issues, for instance data analysis, new products and services development, improvement of our Website, improvement of our products and services.

Ground for processing: the legitimate interests of the Controller. The legitimate interest of the Controller to provide first-class products and services corresponds with the interest of the client and thus is compliant with the provisions of the applicable Bulgarian law for Personal data protection being a sufficient ground for their processing

6) Purpose: Video surveillance of the commercial zone of “TRAMPOLINE PARKS AREA 52” AD

Ground for processing: the legitimate interests of the Controller and in particular to ensure the lawful operation of the Park, to ensure the security and protection of the Park, of the employees and clients during their usage of the Park.

At the territory of the Park under the coverage of the video surveillance are placed the relevant informing signs. The security cameras are working and recording daily on an annual basis, 24 hours.

Data processing term: unless used for investigation aims, claims for damages, court proceedings, etc. in case of incident (e.g. unlawful break through; damage to the property of the Controller; harm to a person on the territory of the premises; or damages of the property of the Controller) the period for archiving of the video surveillance data is 14 days from the date recorded.

1) Disclosure of Personal data according to law 

„TRAMPOLINE PARKS AREA 52“ AD in its capacity of Personal data Controller is subject to Bulgarian law. In special occasions this could impose the provision and/or disclosure of Personal data when required by law, upon request and/or necessity of third parties – state and other authorities, institutions and departments, insurance offices, insurance agents, banks and institutions within the scope of their competence and in compliance with the provisions of the Regulation, Personal Data Protection Act and other provisions of the Bulgarian law.

When possible, we will address such requests to you or will notify you before providing an answer, unless such disclosure is in relation to the prevention or detection of a crime.

2) Disclosure of Personal data to third parties, including Personal data Controllers 

The Personal data we collect could be provided for processing by third parties who act on their own discretion or on behalf of the Personal data Controller in accordance with the provisions of the Regulation and with ensuring the data subject’s rights protection.

Your Personal data could be processed by:

Companies providing services to the Controller, e.g. IT maintenance, IT hosting, usage and maintenance of software products;

Contractual partners (for instance marketing and PR agencies);

Third parties, whose trademarks, products or services are distributed by the Controller;

3) Persons, authorized for the technical processing of your Personal data: representatives and employees of “TRAMPOLINE PARKS AREA 52” AD, engaged with controlling the visits of clients in the Park, logistics, supply, quality assurance, accounting, etc.

4) Transfer of data to countries outside the European economic zone 

The Controller and/or the personal data processing entities could transfer part of your personal data to countries outside the European economic zone only in case the appropriate protection measures apply. In order to ensure adequate level of protection of your Personal data, the Controller has established proper contractual securities in accordance with Chapter 5 of the Regulation and signed Conventional contractual clauses for personal data protection, adopted by the European Commission (controller to process).

5. How do we protect your personal data 

1) We protect personal data in strict compliance with the applicable Bulgarian law and the principles of the framework directives of the European Union for information and personal data protection (including Regulation EU/2016/679).

2) Your Personal data is kept on protected local server (or in particular cases the information is kept on paper as well while observing the required protection requirements). The information is accessible and is being processed in compliance with our privacy policies (or those of our subcontractors or business partners, if applicable), always in accordance with the applicable law and the respective protective measures.

3) We maintain the appropriate technical, physical and organizational measures for Personal data protection against accidental or unlawful deletion or accidental loss, amendment, unauthorized disclosure or access. Although we could not guarantee that the data transfer online or through our Website is lacking all risks of unauthorized disclosure or access, we and our business partners work extra hard in order to maintain adequate measures for your Personal data protection in compliance with the applicable law. For instance we implement the following measures:

Strictly limited and controlled access of our employees and subcontractors to your Personal data, granted only after taking into consideration the realization of the purposes subject to their processing and based on disclosure necessity;

The Personal data is being stored in digital format in data bases, accessible only with individual user name and password and under different levels of access authorization; surveillance is being executed and anti-virus protection; copies and back-up copies for restoring are being made. According to some exceptions, data could be stored on personal computers of the persons having access under ensured protection, similar to the above.

All paper documents which could contain your Personal data are stored in an explicitly designated administrative premise at the territory of the Park in Sofia, Sofia Ring Mall, floor 0 or in the office of our supplier of accounting services “Vistra Corporate Services” EOOD (in regard with contracts with suppliers of goods and services) in Sofia, 2 Tsar Osvoboditel Blvd.
The Park is under video surveillance; fire protection, and established procedures for control of physical access;

The Controller’s staff engaged with the processing of Personal data is familiar with the requirements of the applicable law, with the policies of “TRAMPOLINE PARKS AREA 52” AD, with the existing risks and action scenarios upon their occurrence.

There is also contractual protection considered under the contracts concluded with the Personal data processing entity acting on behalf of the Controller.

6. For what period is your personal data being stored 1. for what period is your personal data being stored 

1) We store your Personal data for as long as necessary for the purposes of its processing. In case your Personal data is being processed for two purposes, we will keep it until the longer period purpose is executed but we will terminate its processing for the shorter term purpose, after the expiry of this shorter term.

2) We limit the access to your Personal data within the range of entities engaged with its processing for the respective purpose.

3) Under specific circumstances we could store your Personal data for a longer periods of time if we are obliged by law, act of a competent authority or in order to have an exact record of your relations with us in case of claims or if we reasonably consider that there is possibility for court proceedings under which your Personal data will be necessary.

4) The storage periods are based on the business needs of the Controller and are in compliance with the applicable law. The Personal data which is no longer needed is being anonymized (the anonymized data could be archived but is no longer related to you) or could be destroyed.

7. Your rights for personal data protection 

You have specific rights related to your Personal data, like for example you have the right to:

  • Request from us to provide you with additional information on the way your personal data is being used;
  • Request from us to provide you with access to your Personal data and provide you with a copy of it;
  • Receive the Personal data related to you and submitted to us in systemized, widely used and suitable for digital reading format and – when technically possible – to transfer this data to other Controller easily if the processing of your Personal data is based on your consent or contract and is executed through automized means;
  • Request from us to update all inaccuracies in the data we store and correct it;
    Request from us to anonymize or delete all data for which we do no longer have legitimate ground for processing;
  • Object to any processing (including profiling) based on legitimate interests if you consider that your fundamental rights and freedoms prevail over our legitimate interests;
  • Object to any processing aiming automatic taking of individual decisions when this is substantially related to you;
  • Request from us to suspend the processing of your Personal data, for instance during a claim investigation;

The exercising of these rights is subject to certain exceptions, for example when the public interest, our interest, or rights and freedoms of others are to be protected. If you exercise some of the above stated rights, we will check the eligibility for such exercising and will reply without unnecessary delay, but within one month. In case of more complex cases or if we have received multiple requests, this period could be prolonged with two more months while informing you in a timely manner.

In case of any questions in regard with your Personal data processing, please contact us at the above provided contact details and single point of contact of the Controller (Monday – Friday from 09h00 until 17h00).

Primary Contact person regarding any issues arising from or related to your Personal data processing, including requests for the exercising of your rights, is the above stated person on behalf of the Controller.

If you are not satisfied with the processing of your Personal data or our reply regarding the exercising of your rights, you could file a claim into the Personal data Protection Commission at Sofia 1592, 2 Tsvetan Lazarov Blvd., website: https://www.cpdp.bg. You could reach the Commission any time, however we will appreciate your attempts to solve any issues directly with us in advance.

8. Cookies 

Our website uses cookies. Please see our Cookie Policy

9. Policy amendments   

The current policy could be amended from time to time. Any amendments under the current policy will enter into force as soon as the amended policy is published on our website. If you use our website or our services after the amendments, this will be considered as consent to the reviewed Policy.

„TRAMPOLINE PARKS AREA 52“ AD