Confidentiality Declaration

Administrator’s dataWE:

HAPPY EAD, UIC 103924544, with address in Bulgaria, Varna Province, Varna Municipality, 9000 Varna, Odesos District, 25 Tsar Osvoboditel Blvd., is a limited liability company, whose major scope of activity is hotel management, restaurant management, catering, trade in food products and all type of commodities.

The personal data we collect from you and subsequently process is:

We provide you with information about us and our activity. To provide some extra information about our products, services, partners and, in general, information other than the one covering the seat and the management address and the one posted on our website, to respond to your enquiries, if and as far as possible, we need to collect information about your full name, email, phone, address, passport data, as provided by you. We guarantee that the information we collect is necessary for the above purposes and does not seek to enter your private space or affect your personal interests and personal life.

Special data categories processed by us:

In relation to the scope of activity of HAPPY EAD we do not process sensitive data of our clients and partners.

 

Source:

We obtain the above personal data from you, personally, or in individual cases, from our business partners and/or third parties.

 

We declare that the personal data we collect will be used for the following purposes:

We need your personal data to both have a connection with you for delivering our products and services ensuring top quality and speed of service and fulfill other lawful obligations.

We process your data on the following grounds:

– Processing is made based on your consent;

– Processing is made to fulfill an agreement with you or when we plan to sign such an agreement;

– Processing is necessary to fulfill our legal obligation – Processing is needed to protect your (vital) interests (or the interests of third party).

 

Consent:

When you agree to accept this notification you authorize us to process your personal data only for the purposes described by us. If needed, we will provide an explicit and written informed consent.

We need your consent to be able to process both types of personal data (standard and special) and this consent should be an explicit one.

You may withdraw your consent at any moment by using a form received by us, filled in and then submitted to us, or draw up such a form (as a free text).

Transfer of personal data to a country outside the EU or to an international organization:

HAPPY EAD does not intent to transfer your personal data to third parties except for the cases provided for in the legislation.

We will neither sell your data to third parties nor shall we transfer these to gain a benefit. We may provide your personal data to parties assisting us in the achievement of the above goals – personal data processors acting based on a written agreement in harmony with our explicit instructions and by applying the adequate technical and organizational measures for your personal data protection. Personal data shall neither be provided to third parties nor shared outside the European Union or the European Economic Area. Recipients of your data may be also officials and authorities having the relevant powers and needing your data to fulfill specific and clear legal obligations. When we intend to provide your special personal data (if you have provided such data) to a third party we will do that only after we have obtained your consent except for the cases where we are obligated to act otherwise based on legislation.

 

CONFIDENTIALITY of the data of the VISITORS of HAPPY EAD where CCTV is used

 

Personal data that we collect and process: If you have visited the seat of our company, or our commercial site having CCTV we will process your data covering image and behavior, giving information about your facial and characteristic features, your behavior, habits, offences and other visible information.

Data source: We, personally, obtain the above personal data.

We declare that the personal data we collect with CCTV will be used only and solely for lawful purposes such as property safeguarding, ensuring security, safety and order, safeguarding public health, or prevention of thefts and other abuses.

Grounds for processing your image and behavioral data: our legitimate interest in guarding, security and protection of public interest. Apart from the above, we may also collaborate with competent public authorities within their powers.

Period of processing: Your data processed with CCTV is stored for up to 60 (sixty) days pursuant to the Private Security Services Act. Generally, this processing is restricted to real-time video surveillance and storage of the relevant recordings.

Total period for data storage

Personal data of the company’s clients are stored for a period up to 5 years as of the conclusion of the relevant agreement with the client. This period is coordinated with the prescription period covering any claims originating from the agreement.

The personal data of job applicants who have not been engaged by the Company, are stored over the period defined within the regulatory framework governing personal data protection, counted as of the procedure finalization, and then they are returned to the person, or destructed. Personal data may be stored for a longer time period in order to make job proposals only with the applicant’s consent provided in writing.

Personal data about the employees of the company is stored pursuant to Bulgarian legislation until expiration of the legal time period after termination of the employment relation.

The recordings from the CCTV at the Company are stored for up to 60 (sixty) days pursuant to the Private Security Services Act. The personal data that the company collects with video surveillance will be used solely for lawful purposes such as property safeguarding, ensuring security, safety and order, safeguarding public health, or prevention of thefts and other abuses.

The personal data contained in accounting documents is stored according to the time periods defined in legislation pursuant to the Accounting Act.

Manner of storage and protection of your personal data processed by us:

We will process your personal data while taking all necessary and sufficient technical and organizational measures for their protection. Alongside, we have adopted the required internal policies and have taken measures for your personal data protection at the design stage. The data officials are well acquainted with the requirements covering your personal data protection. Your personal data is processed to the smallest extent ensuring achievement of the goals set. We have introduced the necessary security measures like safeguarding, restricted access, security systems, etc., we have introduced measures to guarantee permanent confidentiality, completeness and reliability of the systems and the services for processing as well as measures in case of physical or technical failure to timely restore the availability and the access to personal data; we have engineered an internal procedure for regular testing and assessment of the efficiency of the technical and organizational measures guaranteeing the security of processing; we have developed a procedure for data storage and destruction. We will process (collect, store and use) the information provided by you in a manner consistent with the requirements of the General Data Protection Regulation. We will strive to maintain accurate and updated information.

We do not employ automatic decision-making (without human interference) when processing your personal data for any of the above purposes.

 

Your rights as personal data subject are the following:

At any moment while we store or process your personal data you (according to the legal definition – the data subject) are entitled to:

  • Request a copy of your personal data from HAPPY EAD as well as right to access, at any time, to your personal data;

  • Request from HAPPY EAD your personal data in a format convenient for transfer to another personal data administrator, or request by us to transfer this data, with no hindrances on our part;

  • Request from HAPPY EAD to correct, without delay, your inaccurate personal data, as well as the data that is no longer up to date;

  • Request from HAPPY EAD to erase your personal data without unnecessary delay for any of the following reasons:

  • Your personal data is not needed for the purposes it has been collected;

  • You have withdrawn your consent;

  • You have objected to data processing;

  • Processing is unlawful;

  • Personal data should be erased to abide by a legal obligation within the EU law or the law of a member state, applied to HAPPY EAD as a personal data administrator;

  • Your personal data has been collected for offering services to the IT society.

 

We may refuse to erase your personal data for the following reasons:

  • Exercise of the right to freedom of expression and the right to information;

  • To abide by our lawful obligation or to implement an assignment of public interest;

  • Public interest in the field of public health;

  • For archiving purposes in the public interest, scientific or historical research, or for statistical purposes as far as there is a probability that erasure would render impossible, or seriously hinder the said processing; or for ascertainment, exercise or protection of legal claims;

  • You are entitled to request from HAPPY EAD to restrict your personal data processing as in this case data will be only stored nor processed. Our refusal to restriction will be explicit only in writing and we are due to substantiate it with a lawful reason;

  • You are entitled to withdraw your consent for your personal data processing, at any moment, with a separate request sent to the administrator;

  • You are entitled to object to some certain types of processing like direct marketing (non-requested advertising messages);

  • You are entitled to object to automatic processing, incl. profiling;

  • You are entitled not to be subject to decision based solely on an automated processing integrating profiling;

  • If we need to use your personal data for a new goal not subject to this data protection declaration we will communicate a new notification of data protection and, where necessary, will request your prior consent for the new processing.

 

All of the above requests will be forwarded in case a third party (recipients, including outside the EU and international organizations) is involved in your personal data processing.

 

You are entitled to complaint to the supervising authority

You are entitled to lodge a complaint directly to the supervising authority. Such a competent authority is the Personal Data Protection Commission, with address in 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd. (www.cpdp.bg).

If you wish to lodge a complaint concerning your personal data processing through HAPPY EAD you may use the contact details of HAPPY EAD.

 

Conformed by:

Teodora Popova, CEO