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Policy for confidentiality

“Global Biomet” EOOD (the “Company”, “we”, “us”) is a company with long-term history and acting on the Bulgarian market by providing services as carrier of passengers and goods. With the implementation of our business activity, the protection of your data is basic priority for us. Thus we are striving to process such data by reducing the same to the needed minimum and with limiting the terms for their storing, whereas we apply suitable technical and organizational measures for their safety. We value the privacy and inviolability of your life and confidentiality of your personal data.

This Policy for confidentiality is aiming at providing you with general information about the mode and type of personal data that we are processing `respectively that we collect from and for you), why do we need them, to whom they can be provided or disclosed, same as for what period of time these shall be stored. Kindly get acquainted with the present Policy very carefully and do not hesitate to contact us – on the indicated contact requisites – in case you have additional questions, related to the Company’s activity with reference to the processing of personal data or with your rights being subjects of the personal data.

 

  1. Administrator of personal data

The capacity “administrator of personal data” belongs to the person who can personally or jointly with another person define the targets for which such data shall be processed (collected, used and stored) on paper carrier or in electronic form.

The Company shall be acting as administrator of your personal data, in case there is a reason for their processing, for example in connection with the provided by the Company services; for the implementation of your requests, applications and complaints addressed to the Company or related to its activity; for the implementation of contracts with the Company wherein you are a party or representative of a party; for the implementation of or the protection of your complaints against the Company; for the realization of other legislative/ legitimate interests of the Company.

In certain cases the Company can process your personal data and in its capacity of joint administrator with other administrators of personal data, who are also processing on legal bases information about you, same as in the capacity of processing – in the case when the Company has been assigned with such processing. In these cases the Company shall continue to take care about the security and the confidentiality of your data.

 

  1. What types of personal data are being processed by the Company?   

Processed personal data

In connection with our activity related to the provision of services with transportation of passenger and the issuing of tickets, we are processing only your personal data, required by the enacted Bulgarian legislation. Thus, we would like to inform you that when the transported passenger is a child - natural person up to 10 years of age), we shall require presenting of an identification document from the person, accompanying as passenger the child – whereas these documents shall be simply presented to our representative both as evidence as well as for acquaintance. In the case when you are a passenger willing to make use of deduction or discount in the price for transportation of passengers (for example due to the fact that you are school-child, student or retired), we shall ask you to present to us a document, certifying your special quality with respect to which you are asking us for such discount.  In this case you shall have to present to our representative (usually at the ticket sales’ office) the relevant document, certifying the fact that you are really a school-child, student or retired (or that you possess other special qualities, rendering you the right to get a discount) in order to get acquainted with the same. We do not copy the above mentioned documents, which we are requesting from you, but instead we only need to be acquainted with the same, same as to verify their validity and authenticity.  

 

It is important for you to know that in the usual case of purchasing a ticket for travelling with our buses – at the ticket sales’ office – we do not collect and process personal data for you. Notwithstanding this and provided that you want and that it is necessary for you, we may mention your names on the ticket (aiming at its personalization) – but only if you want this and give us two of your names. We are not checking your identity and authenticity of the stated by you names, due to which you alone bear the responsibility about the authenticity of the provided by you data.

 We are processing more personal data about you in the following cases:

  • When making on-line booking of bus tickets as well as when buying on-line bus tickets – since we are aiming at providing you with better, more accessible and efficient service, which shall give you the opportunity to follow-up your trips, to account your costs for the trips as well as to remotely book a certain seat in our buses, chosen by you;
  • While transporting with our vehicles (buses) – due to the fact that we are accomplishing video surveillance in our buses with the aim to ensure safety and constant surveillance of the traffic situation as well as controlling the actions of our drivers, furthermore, because we wish to ensure relevant conditions for comfortable and enjoyable trip. Therefore, that is why it is important for us to secure a free access to wireless internet (Wi Fi), while you are travelling;
  • With the reviewing of your appeals/ requests/ complaints and solving of disputes with you, of importance is our individual approach to your requests and complaints as well as our meeting your expectations and needs in the best possible way;
  • With the establishment of contractual relations with you or with a natural person or legislative entity, which you are representing – because it is important for us to identify the person who is signing the respective contract or document, addressed to us or prepared in connection with certain relations with us, same as assuming for that person or for a third person certain rights and obligations, thus it is actually the person, having representative powers;
  • While providing services related to cargo transportation – i.e. when your data can be processed in connection with the sending or receiving of certain goods as well as with the documentary compilation of the transportation of the goods;
  • With the implementation of business contacts with you – when you yourself  have provided us with contact data with respect to our present or eventual future business ventures, or when your contact data have been provided to us by your employer in connection with the performed by you business functions.

With regards to the above mentioned and depending on the targets for the processing, the Company is able to process (in this number to collect and use) different types of personal data about you, for example:

  • Names
  • Address (permanent, present)
  • Personal Identification Number or another identification number
  • Birth date
  • Copy of identity document 
  • Data about the identity document
  • Telephone numbers
  • Addresses of electronic mail
  • Traffic data
  • Data about your location
  • Data about your seat in the buss
  • Data about IP addresses
  • Video images.

The Company is applying directly and immediately the principle for minimizing the processed personal data. The kinds of personal data being processed are specified in compliance with the specificity of the Company’s activity and the directly related thereto risks, imposing the necessity for the Company to undertake measures for safety of the transported goods as well as measures for the safety and comfort of the transported passengers.

 From you – as clients – the Company is not collecting and using personal data, disclosing racial or ethnic origin, religious or philosophic beliefs or membership in trade unions’ organizations, same as the processing of genetic data, biometric data for the purposes solely of the identification of the natural person, data about the health state or data about the sexual life or the sexual orientation of the natural person, due to which in the course of the communication with the same, you are not supposed to disclose such data.

Processed technical data which are rendering the possibility to individualize you

When using our website https://www.biomet.bg/ (“Website”), the Company is not collecting information about you, which by itself has the character of “Personal data”.

In any case it is important for you to know that with the visits to our website, the Company collects information about you, which can be qualified as “personal data” solely and only with the processing in combination with other information about you, collected in connection with the work, needed for the website. Such is the information (the data), showing your consumer interests and behavior. These other data are being processed in connection with the functioning of the website and the adequate provision of the declared by you services, provided through the website (temporary data (cookies) as well as other technical data such as recording on your device, by means of which you are accessing to the browser, wherein the website is functioning). These other data are more specifically including the following information:

  • Information about your browser;
  • Information, acquired from files “cookies”, utilization of pixel tags and other technologies;
  • Demographic information as well as other information, ensured by you; and
  • Summarized information from the using of internet site.

These data are used by the Company for the improvement of the website operation, for the improvement of the consumer’s appearance of the website, for the facilitation of the management of the sites, for the acquiring of information for the consumer’s habits and for the targeted advertisements.

We and our suppliers of services – third persons – can receive these other data in different ways, including:

  • Through your internet browser: Most of the internet sites are collecting certain type of information, as for example your IP address (i.e. the address of your computer in internet), resolution on the screen, type of the operating system (Windows or Mac) as well as version, type and version of the internet browser, time and duration of the visit in our internet site (sites). We use this information for purposes, such as estimating the level of attendance in our internet site, diagnosing problems with the server and management of the internet site.
  • Using of files “cookies”: The “cookies” are small text files which are preserved in your computer or mobile device when you visit a certain website. They allow the website to memorize your activities and preferences (as for example the user’s name, language, print size and other display settings) for a certain period of time, in order to avoid introducing them every time, when you are visiting the site or when you pass from one page to another. By itself, the cookie does not contain and is not collecting information, except when it is read out by a server through a web browser; it can provide information with the aim to reach a more-suitable service for the user through registration, together with the other data, as well as for the preferences of the user, by means of identification of mistakes and/ or collecting of data for statistical purposes. These files will not hurt your computer, but instead will allow us to recognize your computer and to collect information such as type of the browser, time, spent in the internet site, visited sites, language preferences and the respective country on the internet site.

Herein below there is a description of the files “cookies”, which we use on our internet site for Republic of Bulgaria, what is their function, what are the data that they collect and how we use them.

  • Session cookies – They are necessary for the implementation of important functions of the website, as for example memorizing a repeated field of a form in the frames of one session of the browser. Furthermore, they are assisting for the restricting the necessity of transfer of information in the internet space. These are not stored on your computer and are being erased, when you terminate the session of your browser. It is of importance for you to be informed that we cannot guarantee the correct using of the Website without the use of cookies.
  • Permanent cookies – These cookies are used together with other items for defining the frequency of what, when and how often are the sites used, how long have the users remained on a certain site. If you are to learn more about the “cookies” on Google Statistic, kindly look here (https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage). These cookies boost the following of the traffic to the Website.
  • Targeting and advertising cookies – These cookies shall be used for the purpose of showing you contents and advertisements, related to your interests as users (.doublecheck.net.cookies). These cookies are stored in your computer and cannot be used for the identification of the individuals.

It is important for you to know that we can use redirecting marketing services, such as the one in Google AdWords, in order to adapt our advertisements especially for you. You can deactivate the commands of these cookies from Google Ad Preferences Manager. For more information about the Policy of Google ads please see here (https://policies.google.com/privacy?hl=en).

Shortened information about the cookies can be found here.

You can state a denial of receipt of files “cookies” from the settings in your browser. But if you do not accept the using of these “cookies”, you may experience certain inconveniences with the use of the Website. As well as some on-line services. You can also delete all cookies which have already been saved in your computer, whereas you can also set more browsers to interlock them. If you do this however, you may have to manually set some parameters each time when you visit a certain site and besides it is possible that some services and functions may not work.

We are collecting personal data for you also through your registration and/ or through your activities related to the booking of a ticket for passengers’ transportation, made through the Website https://busticket.bg/. It is important for you to know that this Website is maintained by our partner (“IBS Bulgaria” EOOD), with whom we are in contractual relations and with respect to the latter we have placed very high requirements for the safety of your data. Through the Website of our Partner, the Company is able to present for you a more comfortable way for buying tickets for passengers’ transportation, namely the service “on-line bus tickets”. With the utilization of the Website, you are providing personal data, needed for the creation of a booking of a ticket for passengers’ transport, for the recording of the sale of a ticket same as for the issuing of a ticket for passenger transport. Keeping in mind the fact that the Website https://busticket.bg/ is maintained by a third for the Company person/ entity, we are encouraging you to get acquainted in details with the General provisions of this Website and with the published therein Policy about the personal data. Kindly keep in mind that with the aim to get an on-line bus ticket, you have the possibility to pay with a Bankcard also, which shall be related to processing of additional personal data about you, including for possessed by you means for payment.     

   3.How is the Company collecting and processing your personal data?

As we have already indicated, the objectives for which the Company is processing your personal data are as follows:

  • Provision of services by the Company as well as implementation of the concluded by it contracts;
  • Implementation of your requests, applications, petitions and appeals to the Company or related to its activity;
  • Protection of the rights and the interests of the Company in connection with the implementation of contracts, wherein you are a party or a representative of a party;
  • Implementation of legislative liabilities;
  • Accomplishment of legislative/ legitimate interests of the Company, related to the implemented by it commercial activity, business processes or direct marketing;
  • Direct marketing.

With respect to reaching the indicated targets, the Company collects data about you in different ways, whereas most often the processed personal data are provided personally by you. There are other sources as well, from which the Company can receive information about you, for example – from our partner, taking care of the Website https://buticket.bg; by our partners; from your representatives; from your employer; from a sender of a certain cargo, which has to be supplied personally to you or as representative; from official registers (such as the Property register, the Commercial register, the Central register of the special bets, the Central credit register, etc.); from data bases of government bodies (the National insurance fund, the National Revenue Agency, etc.); from our devices for video surveillance and/ or for information coherency with INTERNET.

The Company is processing your personal data by means of different operations related to the processing (in this number, but not only through: collecting, registration, organization, structuring, storing, adapting or amending, deriving, consulting, utilization, disclosing by means of transmission, distribution or another way, in which the data become accessible, aligning or combining, restricting, deleting or destroying), accomplished manually or automatically. The type and mode of accomplishment of the specific operations related to the processing depend on the assigned targets for the processing as well as by the business processes, related to these targets. In the course of its activity for the processing, the Company may use processing operators, with reference to this it shall exercise regular control on the observation of the requirements for high level of security and confidentiality of the processed personal data.

It is important to note that your consent for processing of personal data is not the only legislative grounds with which the Company substantiates its activity for the processing of data. Due to this the Company shall process legally information about you even if you do not explicitly agree with this processing or if you have given your consent, you have exercised your right to withdraw the so given consent for processing.

In  this connection we would like you to take into account that for the purposes indicated herein above when your consent is not a needed prerequisite for the processing of your personal data,  the Company may ask you to provide information or to disclose/ provide such information to third persons on  the grounds, related to the realization of  its legislative/legitimate interests as well (for example with regards to ensuring of the safety in our buses, with regards to the successful implementation of our commercial activity, your strategy and so on). The safety of your data is a priority for us and notwithstanding the need for the accomplishment of legal/legitimate interests of the Company, for the protection of your data we shall apply appropriate technical and organizational protection measures.

The specifics of the Company’s commercial activity require the processing of personal data and due to this it is important to note the fact that if you do not want to provide us with any of the required by us data, it is probable that the Company may not be able to offer/ provide the services which you are interested in, or the assistance which you may require, or to prepare suggestions, conforming to your specific needs.

 

      4. Who will have access to your personal data?  

The Company guarantees that your personal data shall be processed only in compliance with the targets, mentioned herein above. In connection with these objectives, your data can be provided/ disclosed/ forwarded to third persons, acting as administrators of personal data, such as for example:

  • Governmental and other public bodies (such as municipalities, bodies of the internal affairs in Republic of Bulgaria and of third countries; other control bodies);
  • Courts, prosecution, notaries, private bailiffs;
  • Our partners in connection with the spedition activity, with the transportation of goods and transportation of passengers;
  • “IBS Bulgaria” EOOD and/ or other companies, operating/ managing booking systems or for on-line trading with tickets for passenger transport.

 

In connection with the mentioned objectives, we may also provide your data to persons, acting as data processing operators or as joint administrators, with respect to which the Company has the capacity of administrators, such as:

  • Other companies from our group;
  • Our commissioners, serving ticket centers or assisting us in connection with the selling of our services;
  • Technical advisors, solicitors, accountants, same as companies whereby we provide the performance of specific activity (e.g. IT- support, etc.);
  • The official in charge for the personal data protection provided that the same is external consultant.

 

   Besides the cases, indicated above, it is also possible to provide your personal data to third persons:

  • With planning or actual reorganization of the Company, such as merging, sale of enterprise, same as any other alienation of part of our activity or assets, including with the inconsistency procedure;
  • In order to observe the legal obligation, including and for example procedure, initiated after your alert/ complaint;
  • In order to ensure the due and precise development of procedures, related to investigation of road accidents.

As indicated herein above, the security of your personal data is our priority and due to this the Company will not disclose/ provide/ submit your data to third persons, not having substantiated right to find out information about you.

 

     5.Where shall your personal data be processed?

Your data shall be basically processed on the territory of Republic of Bulgaria and within the frames of the European Union. In rare cases, your personal data may also be processed outside the European Union, whereas there shall always exist contractual restrictions with reference to the confidentiality and the protection of the data in compliance with the applicable requirements, stipulated in the enacted legislation in Republic of Bulgaria. Similar processing of personal data outside the territory of the European Union is possible to occur with the using of informative services for communication (including after your initiative) – for example via e-mails or applications for communication, when the used e-mail servers are based on hardware devices, located outside the territory of the European Union.

With regards to the place for the processing of your data it should be noted that the Company may also use “cloud” technology for the processing of your data. In this connection, we would also like you to know that the Company’s practice requires the conclusion of a contract with the suppliers of similar technologies, containing explicit instructions regarding the measures for data protection as well as for their confidentiality, whereas the suppliers are obliged to observe. Provided that the engaged by the Company processing operators use for the purposes of their activity similar technologies, the Company is placing its requirements to the processing operators and looks after the observance by the latter to apply and require from the suppliers of “cloud” technologies the application on high level of protection of the processed by these technologies data. Notwithstanding the indicated it is important to take into account the fact that the suppliers of “cloud” technologies by default apply enforced protection measures, ensuring considerably high level of data protection.

 

     6.What are your rights in connection with your personal data?

The perceived by us practices and methodologies concerning the data protection and ensuring the information security assign the parameters of the established measures, oriented towards:

  • guaranteeing the confidentiality of the information by applying a system of approved restrictions on the access and disclosure of information;
  • ensuring the integrity of the information by means of protection against illegal changes or deletion of information;
  • ensuring accessibility of the information by means of reliable and due access to  the information;
  • reaching accountability of the information – by introducing of control on the access and the rights over the information systems.

In your capacity of subject of personal data, by virtue of Regulation (EC) 2016/679 of the European Parliament and of the Council from April 27th 2016 concerning the protection of the natural persons in connection with the processing of personal data and the free movement of such data (“The general regulation for data protection”), you are allowed to have the following rights:

  • right to access your data – upon request from your side, we shall provide information about your data, being processed;
  • right to correct your data – in case you consider that certain data, being processed are no longer actual or are incorrect due to another reason, you shall have the right to request correction of the data, being processed;
  • right to delete your data (right “to be forgotten”) – you have the right to request deletion of the data, which we are processing about you, whereas we shall respect your request only in case there is no longer legal reason for us to continue processing your data. Relevantly, for us it is possible to partially respect your request for deletion.
  • right to restrict the processing – you have the possibility to exercise this right only when you have contested the preciseness of the processed data, whereas the restriction on the processing can only be for the period during which we are verifying the correctness of your data; when the processing is illegal, but you are contesting the deletion of the data; when we no longer need your data for the purposes of the processing, but you as a subject of personal data require them for the establishment, the exercising or the protection of your legal claims; when you have objected against the processing and a verification is expected to see whether the legislative interests of the administrator has an advantage to your interests as subject of personal data;
  • right for the portability of the data – you can ask us to transfer all or part of your data, which are being processed and which you personally have submitted to us, to you or to another administrator in format, adapted for machine reading, when the processing of these data is on the grounds of your consent or on the grounds of implementation of contract and when the processing is implemented with automated means;
  • right to object against the automated processing of your data, against processing by profiling as well as against processing for the purposes of the direct marketing – we are providing you with the possibility to exercise this right at any time and absolutely free of charge;
  • right to information for violating the safety – you have the right to be dully informed about each violation on the security of your data and we shall fulfill our obligation in this relation, by publishing on the Website information for each violation of this kind, same as we can send you information by e-mail, when you have submitted one and when it is correct.
  • right to object against processing for the purposes of direct marketing – you have the right, at any time and free of charge, to change your marketing preferences same as to withdraw an already given consent for the processing of your personal data for the purposes of the direct marketing or to object against such processing;
  • right to withdraw a given consent for processing of personal data – you have right, at any time and free of charge, to withdraw an already given by you consent for the processing of personal data. We would like you to know that your consent is not the only reason for processing of your personal data, thus it is possible for us to continue processing your personal data even after the withdrawing of your consent.

 

You may exercise the described rights with changes in the settings on your browser or mobile application, as long as this is technically possible, or by getting in touch with us by using the information for contacts, indicated herein above, by completing the Form for exercising the rights, in conformity with the General regulation for data protection, which can be found on the following website (https://www.biomet.bg/) or in our ticket centers and then file it in the Company on paper carrier in a respective ticket center or by mail to our address of management or by mailing it to the e-mail address, indicated in the Website as data for contacting the Company.

Taking into account the fact that the Company is getting in contact (is establishing legal relations) with different categories of persons and this in connection with different causes (including as a result of your factual and indirect participation in certain events), the correct reviewing of the filed in by you application for exercising rights is directly connected with the exact establishing by you of circumstances, under which it has been mandatory for the Company to process your personal data.

With the exercising of your rights as a subject of personal data, a necessity occurs for the Company to require and process certain personal data for you for the purposes of the establishing and verification of your identity. As personal data administrator, the Company is not only obliged to ensure the way for the exercising of your rights, but it is also obliged to guarantee that these rights shall be exercised only by the subjects which are actually the holders of the respective rights, arranged with the General regulation for protection of the data.

Your application for exercising the rights shall be dully reviewed, in the most common case for not more than 30 (thirty) calendar days, except if your request is not specific and not related to  the thorough investigating the information. In any case our team shall make the necessary to inform you by mailing the information by e-mail, in case of delaying the reviewing of your application. Keeping in mind the fact that the Company highly appreciates the need of data protection, the same has approved and applies a procedure for reviewing the applications for exercising of rights pursuant to the General regulation for data protection, wherein the terms for processing and replying are scheduled with the filing of an application for exercising the rights by a subject of data.

In addition to the above stated, it is important for you to be informed that in certain rare hypothesis (for example death of a subject of personal data) you can also exercise the rights of another subject of personal data. In such a case together with the application (Form for exercising rights pursuant to the General regulation for data protection) you shall have to present also documents, certifying your relation (family relations) with the subject of the personal data, whose right you are willing to exercise.  

      

     7. How can you object against the processing of your personal data?

As we have indicated, you have the right to object against the processing of your personal data by the Company or to terminate the processing (incl. for the purposes of the direct marketing). After you have notified us about this will, we shall terminate the processing of your personal data, except if the same is not permitted or is not reasoned with regards to the presence of another legislative bases for processing. If in the course of the processing process we have disclosed your personal data to third persons, we shall immediately notify these persons about the exercised by you objection.

  

 8. How long shall the Company store your personal data?

The term for processing of your data is also in concordance with the objectives of the processing as well as with the normative requirements for storing of accounting and taxation information. The defining of the specific term for storing of your personal data is directly conditioned by the type of the relations which we have established with you and with reference to which we have processed personal data about you. So, for example, in connection with our activity related to the sale of tickets for bus transportation through our ticket centers, we usually do not collect and do not register your personal data (our officers may eventually get acquainted with your personal data by looking at the presented certain documents for identification). As a result, in these cases we will not store any personal data about you. If however, you have requested personalization of purchased by you ticket for bus transportation, we shall collect and store your personal data and we shall delete them after expiration of one year from the date of receiving the data.

The Company will not store your personal data longer than needed and will store them only in connection with the objectives, for which the same have been collected.   

     9. How can you get in touch with us?

“Global Biomet” EOOD
Sofia 1407, No. 35, “Nikola Vaptsarov” Blvd.
Phone: +359 (2) 86 89 441; 86 89 443
You may contact us on the following e-mail: [email protected] or through the for inquiring, published on https://biomet.bg/kontakti

Data protection officer:
Name: Kiril Petrov
E-mail: [email protected]
Telephone: +359876-667-454

In connection with the collection and processing of your personal data you may also turn to the Commission for personal data protection on the following address: Sofia 1592, No. 2 “Prof. Tsvetan Lazarov”; www.cpdp.bg.

     10. When is this Policy updated?

We are reviewing the present Policy regularly. The actual version can be discovered on our site: https://www.biomet.bg/, whereas we shall inform you about each significant change, which could concern you, by means of publishing information about the changes. The last updating of the current declaration is from 20.05.2018.