Privacy Policy
Mandatory information on the rights of individuals regarding the protection of personal data (Privacy Policy)
General information
From May 25, 2018, a new regulation on the protection of personal data (General Data Protection Regulation), adopted by the European Union, comes into force. The regulation aims to guarantee the protection of data of individuals from all EU member states and to unify the regulations for their processing.
As a personal data administrator, DM ASET OOD meets all the requirements of the new regulation, by collecting only data of individuals to the extent necessary for the provision of the service, and keeping them responsibly and legally.
Information about the Administrator of personal data
1. Name DM ASSET OOD
2. UIC/BULSTAT: 207208493
3. Registered office and address of management: Varna, 64 Hristo Smirnenski Str.
4. Correspondence details: Varna, 64 Hristo Smirnenski Str.
5. E-mail: info@trinavisapartments.com
Information about the competent supervisory authority
1. Name: Commission for Personal Data Protection
2. Registered office and address of management: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Telephone: 02 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg
DM ASSET OOD carries out 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 individuals 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) DM ASSET OOD collects and processes your personal data on the basis of the following:
● Performance of DM ASSET OOD's obligations under a contract with you;
● Explicit consent obtained from you upon inquiry through the DM ASSET OOD website https://www.trinavisapartments.com
● For the purposes of the legitimate interest of DM ASSET OOD.
Purposes and principles for collecting, processing and storing your personal data
Art. 2. (1) DM ASSET OOD collects and processes the personal data that you provide to us in connection with the use of our services and for concluding a contract with the company, as well as for inquiries through the DM ASSET OOD website, including for the following purposes:
● individualization of a party to the contract;
● accounting purposes;
● protection of information security;
● ensuring the performance of the contract for the provision of the relevant service;
(2) DM ASSET OOD complies with the following principles when processing your personal data:
● lawfulness, good faith and transparency;
● limitation of the purposes of processing;
● relevance to the purposes of processing and minimization of the collected data;
● accuracy and timeliness of the data;
● limitation of storage in order to achieve the purposes;
● integrity and confidentiality of the processing and ensuring an appropriate level of security of the personal data.
(3) When processing and storing personal data, DM ASSET OOD may process and store personal data in order to protect its following legitimate interests:
● fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.
What types of personal data does DM ASSET OOD collect, process and store?
Art. 3. (1) DM ASSET OOD performs the following operations with personal data for the following purposes:
● Conclusion and execution of a commercial transaction with a client or partner
(2) DM ASSET OOD processes the following categories of personal data and information for the following purposes and on the following grounds:
● Data: Your individualizing data: Names on ID card or passport, Personal Identification Number/Personal Identification Number, citizenship, ID card number/valid national identity document, address, email and telephone.
○ Purpose for which the data is collected: 1) execution of a contract with a business partner and its administration;;
○ Ground for processing your personal data – contractual basis
● Additional data provided by you – If you wish to make an inquiry via the DM ASSET OOD website: https://www.trinavisapartments.com, you must fill out an online form that requires: name, surname, email and telephone.
○ Purpose for which the data is collected: Inquiry for information about the activities and services of DM ASSET OOD.
○ Grounds for data processing: By accepting the general terms and conditions and the privacy policy of the website, you expressly consent to your personal data being processed for the relevant purpose.
● Other data that DM ASSET OOD processes – When entering our website, DM ASSET OOD collects data about the IP address used.
○ Purpose for which the data is collected: Improving the security of the service and localization of the interface, statistical and marketing research.
○ Grounds for data processing: The IP address is collected on the basis of the legitimate interests of the administrator – Art. 6, para. 1, b. (f) of the GDPR;
● Your data for issuing an invoice to an individual – If you wish to be issued an invoice in your capacity as an individual, you should provide your national identification number.
○ Purpose for which the data is collected: Issuing an invoice for making payments under a concluded contract for the provision of services.
○ Grounds for processing your personal data – Upon concluding a written contract, a contractual relationship is created between DM ASSET OOD and you, on the basis of which we process your personal data – Art. 6, para. 1, b. (b) of the GDPR.
(3) DM ASSET OOD does not collect and does not process personal data that relate to the following:
● reveal racial or ethnic origin;
● reveal political, religious or philosophical beliefs, or membership in trade unions;
● genetic and biometric data, health data or data on sex life or sexual orientation.
(4) Personal data are collected by DM ASSET OOD from the persons to whom they relate.
(5) The company does not carry out automated decision-making with data.
Storage period of your personal data
Art. 4. (1) DM ASSET OOD stores your personal data for a period not longer than the requirements of the applicable legislation for the respective period provided. After the expiry of this period, DM ASSET OOD takes the necessary care to delete and destroy all your data without undue delay.
(2) DM ASSET OOD notifies you in the event that the data storage period needs to be extended in order to fulfill the purposes, perform the contract, in order to pursue legitimate interests of DM ASSET OOD or otherwise.
Transfer of your personal data for processing
Art. 5. (1) DM ASSET OOD may, at its own discretion, transfer part or all of your personal data to processors of personal data for the fulfillment of the processing purposes in compliance with the requirements of Regulation (EU) 2016/679.
(2) DM ASSET OOD shall notify you in case of intention to transfer part or all of your personal data to third countries or international organizations.
Your rights in the collection, processing and storage of your personal data
Withdrawal of consent to the processing of your personal data
Art. 6. (1) If you do not want all or part of your personal data to continue to be processed by DM ASSET OOD for specific or all processing purposes, you may withdraw your consent to processing at any time by filling out an online form or by making a free text request.
(2) DM ASSET OOD may request that you verify your identity and identity with the person to whom the data relate.
Right of access
Art. 7. (1) You have the right to request and receive from DM ASSET OOD confirmation as to whether personal data relating to you are being processed.
(2) You have the right to access the data relating to it, as well as the information relating to the collection, processing and storage of your personal data.
(3) DM ASSET OOD shall provide you upon request with a copy of the processed personal data relating to you, in electronic or other appropriate form.
(4) Providing access to the data is free of charge, but DM ASSET OOD reserves the right to impose an administrative fee in case of repetitive or excessive requests.
Right to correction or completion
Art. 8. You may correct or complete inaccurate or incomplete personal data relating to you by submitting a request to DM ASSET OOD.
Right to erasure (“to be forgotten”)
Art. 9.(1) You have the right to request from DM ASSET OOD the erasure of personal data relating to you, and DM ASSET OOD has the obligation to erase them without undue delay where one of the following grounds applies:
● the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
● you withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;
● you object to the processing of personal data relating to you, including for direct marketing purposes and there are no overriding legal grounds for the processing;
● the personal data have been processed unlawfully;
● the personal data must be erased for compliance with a legal obligation under EU law or the law of a Member State to which DM ASSET OOD is subject;
● the personal data have been collected in connection with the provision of information society services.
(2) DM ASSET OOD is not obliged to delete personal data if it stores and processes them:
● for the exercise of the right to freedom of expression and the right to information;
● for compliance with a legal obligation which requires processing, provided for in EU law or the law of the Member State to which the Administrator is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in it;
● for reasons of public interest in the field of public health;
● for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;
● for the establishment, exercise or defense of legal claims.
(3) In order to exercise your right to be "forgotten", you should submit a written request sent to DM ASSET OOD, as well as verify your identity and identity with the person to whom the data relates, by presenting your ID card on site for identification purposes
(4) DM ASSET OOD does not delete the data that it has a legal obligation to store, including for protection in connection with legal claims made against it or proving its rights.
Right to restriction
Art. 10. You have the right to request DM ASSET OOD to restrict the processing of data relating to you when:
● you contest the accuracy of the personal data, for a period that allows DM ASSET OOD to verify the accuracy of the personal data;
● the processing is unlawful, but you do not want your personal data to be deleted, but only their use to be restricted;
● DM ASSET OOD no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
● You have objected to the processing pending verification of whether the legitimate grounds of DM ASSET OOD override your interests.
Right to portability
Art. 11. (1) You may at any time obtain the data stored and processed about you in connection with the use of the services of DM ASSET OOD by sending a request by email.
(2) You may request DM ASSET OOD to directly transmit your personal data to a controller designated by you, where technically feasible.
Right to information
Art. 12. You may request DM ASSET OOD to inform you of all recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested have been disclosed. DM ASSET OOD may refuse to provide this information if this would be impossible or would require disproportionate effort.
Right to object
Art. 13. You may object at any time to the processing of personal data by DM ASSET OOD that concerns you, including if they are processed for the purposes of profiling or direct marketing.
Your rights in the event of a breach of the security of your personal data
Art. 14. (1) If DM ASSET OOD becomes aware of a breach of the security of your personal data that may result in a high risk to your rights and freedoms, we will notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.
(2) DM ASSET OOD is not obliged to notify you if:
● has taken appropriate technical and organizational measures to protect the data affected by the security breach;
● has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;
● notification would require disproportionate efforts.
Persons to whom your personal data are provided
Art. 15. The administrator does not transfer your data to third countries.
Other provisions
Art. 16. In case of violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission, as follows:
1. Name: Personal Data Protection Commission
2. Registered office and address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Telephone: 02 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg
Art. 17. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are not mandatory and you can make your requests in any form that contains a statement to this effect and identifies you as the data owner.
Art. 18. If the consent concerns a transfer, the Administrator shall describe the possible risks of the transfer of data to third countries in the absence of an adequate protection solution and appropriate remedies.
General information
From May 25, 2018, a new regulation on the protection of personal data (General Data Protection Regulation), adopted by the European Union, comes into force. The regulation aims to guarantee the protection of data of individuals from all EU member states and to unify the regulations for their processing.
As a personal data administrator, DM ASET OOD meets all the requirements of the new regulation, by collecting only data of individuals to the extent necessary for the provision of the service, and keeping them responsibly and legally.
Information about the Administrator of personal data
1. Name DM ASSET OOD
2. UIC/BULSTAT: 207208493
3. Registered office and address of management: Varna, 64 Hristo Smirnenski Str.
4. Correspondence details: Varna, 64 Hristo Smirnenski Str.
5. E-mail: info@trinavisapartments.com
Information about the competent supervisory authority
1. Name: Commission for Personal Data Protection
2. Registered office and address of management: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Telephone: 02 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg
DM ASSET OOD carries out 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 individuals 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) DM ASSET OOD collects and processes your personal data on the basis of the following:
● Performance of DM ASSET OOD's obligations under a contract with you;
● Explicit consent obtained from you upon inquiry through the DM ASSET OOD website https://www.trinavisapartments.com
● For the purposes of the legitimate interest of DM ASSET OOD.
Purposes and principles for collecting, processing and storing your personal data
Art. 2. (1) DM ASSET OOD collects and processes the personal data that you provide to us in connection with the use of our services and for concluding a contract with the company, as well as for inquiries through the DM ASSET OOD website, including for the following purposes:
● individualization of a party to the contract;
● accounting purposes;
● protection of information security;
● ensuring the performance of the contract for the provision of the relevant service;
(2) DM ASSET OOD complies with the following principles when processing your personal data:
● lawfulness, good faith and transparency;
● limitation of the purposes of processing;
● relevance to the purposes of processing and minimization of the collected data;
● accuracy and timeliness of the data;
● limitation of storage in order to achieve the purposes;
● integrity and confidentiality of the processing and ensuring an appropriate level of security of the personal data.
(3) When processing and storing personal data, DM ASSET OOD may process and store personal data in order to protect its following legitimate interests:
● fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.
What types of personal data does DM ASSET OOD collect, process and store?
Art. 3. (1) DM ASSET OOD performs the following operations with personal data for the following purposes:
● Conclusion and execution of a commercial transaction with a client or partner
(2) DM ASSET OOD processes the following categories of personal data and information for the following purposes and on the following grounds:
● Data: Your individualizing data: Names on ID card or passport, Personal Identification Number/Personal Identification Number, citizenship, ID card number/valid national identity document, address, email and telephone.
○ Purpose for which the data is collected: 1) execution of a contract with a business partner and its administration;;
○ Ground for processing your personal data – contractual basis
● Additional data provided by you – If you wish to make an inquiry via the DM ASSET OOD website: https://www.trinavisapartments.com, you must fill out an online form that requires: name, surname, email and telephone.
○ Purpose for which the data is collected: Inquiry for information about the activities and services of DM ASSET OOD.
○ Grounds for data processing: By accepting the general terms and conditions and the privacy policy of the website, you expressly consent to your personal data being processed for the relevant purpose.
● Other data that DM ASSET OOD processes – When entering our website, DM ASSET OOD collects data about the IP address used.
○ Purpose for which the data is collected: Improving the security of the service and localization of the interface, statistical and marketing research.
○ Grounds for data processing: The IP address is collected on the basis of the legitimate interests of the administrator – Art. 6, para. 1, b. (f) of the GDPR;
● Your data for issuing an invoice to an individual – If you wish to be issued an invoice in your capacity as an individual, you should provide your national identification number.
○ Purpose for which the data is collected: Issuing an invoice for making payments under a concluded contract for the provision of services.
○ Grounds for processing your personal data – Upon concluding a written contract, a contractual relationship is created between DM ASSET OOD and you, on the basis of which we process your personal data – Art. 6, para. 1, b. (b) of the GDPR.
(3) DM ASSET OOD does not collect and does not process personal data that relate to the following:
● reveal racial or ethnic origin;
● reveal political, religious or philosophical beliefs, or membership in trade unions;
● genetic and biometric data, health data or data on sex life or sexual orientation.
(4) Personal data are collected by DM ASSET OOD from the persons to whom they relate.
(5) The company does not carry out automated decision-making with data.
Storage period of your personal data
Art. 4. (1) DM ASSET OOD stores your personal data for a period not longer than the requirements of the applicable legislation for the respective period provided. After the expiry of this period, DM ASSET OOD takes the necessary care to delete and destroy all your data without undue delay.
(2) DM ASSET OOD notifies you in the event that the data storage period needs to be extended in order to fulfill the purposes, perform the contract, in order to pursue legitimate interests of DM ASSET OOD or otherwise.
Transfer of your personal data for processing
Art. 5. (1) DM ASSET OOD may, at its own discretion, transfer part or all of your personal data to processors of personal data for the fulfillment of the processing purposes in compliance with the requirements of Regulation (EU) 2016/679.
(2) DM ASSET OOD shall notify you in case of intention to transfer part or all of your personal data to third countries or international organizations.
Your rights in the collection, processing and storage of your personal data
Withdrawal of consent to the processing of your personal data
Art. 6. (1) If you do not want all or part of your personal data to continue to be processed by DM ASSET OOD for specific or all processing purposes, you may withdraw your consent to processing at any time by filling out an online form or by making a free text request.
(2) DM ASSET OOD may request that you verify your identity and identity with the person to whom the data relate.
Right of access
Art. 7. (1) You have the right to request and receive from DM ASSET OOD confirmation as to whether personal data relating to you are being processed.
(2) You have the right to access the data relating to it, as well as the information relating to the collection, processing and storage of your personal data.
(3) DM ASSET OOD shall provide you upon request with a copy of the processed personal data relating to you, in electronic or other appropriate form.
(4) Providing access to the data is free of charge, but DM ASSET OOD reserves the right to impose an administrative fee in case of repetitive or excessive requests.
Right to correction or completion
Art. 8. You may correct or complete inaccurate or incomplete personal data relating to you by submitting a request to DM ASSET OOD.
Right to erasure (“to be forgotten”)
Art. 9.(1) You have the right to request from DM ASSET OOD the erasure of personal data relating to you, and DM ASSET OOD has the obligation to erase them without undue delay where one of the following grounds applies:
● the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
● you withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;
● you object to the processing of personal data relating to you, including for direct marketing purposes and there are no overriding legal grounds for the processing;
● the personal data have been processed unlawfully;
● the personal data must be erased for compliance with a legal obligation under EU law or the law of a Member State to which DM ASSET OOD is subject;
● the personal data have been collected in connection with the provision of information society services.
(2) DM ASSET OOD is not obliged to delete personal data if it stores and processes them:
● for the exercise of the right to freedom of expression and the right to information;
● for compliance with a legal obligation which requires processing, provided for in EU law or the law of the Member State to which the Administrator is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in it;
● for reasons of public interest in the field of public health;
● for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;
● for the establishment, exercise or defense of legal claims.
(3) In order to exercise your right to be "forgotten", you should submit a written request sent to DM ASSET OOD, as well as verify your identity and identity with the person to whom the data relates, by presenting your ID card on site for identification purposes
(4) DM ASSET OOD does not delete the data that it has a legal obligation to store, including for protection in connection with legal claims made against it or proving its rights.
Right to restriction
Art. 10. You have the right to request DM ASSET OOD to restrict the processing of data relating to you when:
● you contest the accuracy of the personal data, for a period that allows DM ASSET OOD to verify the accuracy of the personal data;
● the processing is unlawful, but you do not want your personal data to be deleted, but only their use to be restricted;
● DM ASSET OOD no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
● You have objected to the processing pending verification of whether the legitimate grounds of DM ASSET OOD override your interests.
Right to portability
Art. 11. (1) You may at any time obtain the data stored and processed about you in connection with the use of the services of DM ASSET OOD by sending a request by email.
(2) You may request DM ASSET OOD to directly transmit your personal data to a controller designated by you, where technically feasible.
Right to information
Art. 12. You may request DM ASSET OOD to inform you of all recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested have been disclosed. DM ASSET OOD may refuse to provide this information if this would be impossible or would require disproportionate effort.
Right to object
Art. 13. You may object at any time to the processing of personal data by DM ASSET OOD that concerns you, including if they are processed for the purposes of profiling or direct marketing.
Your rights in the event of a breach of the security of your personal data
Art. 14. (1) If DM ASSET OOD becomes aware of a breach of the security of your personal data that may result in a high risk to your rights and freedoms, we will notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.
(2) DM ASSET OOD is not obliged to notify you if:
● has taken appropriate technical and organizational measures to protect the data affected by the security breach;
● has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;
● notification would require disproportionate efforts.
Persons to whom your personal data are provided
Art. 15. The administrator does not transfer your data to third countries.
Other provisions
Art. 16. In case of violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission, as follows:
1. Name: Personal Data Protection Commission
2. Registered office and address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Telephone: 02 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg
Art. 17. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are not mandatory and you can make your requests in any form that contains a statement to this effect and identifies you as the data owner.
Art. 18. If the consent concerns a transfer, the Administrator shall describe the possible risks of the transfer of data to third countries in the absence of an adequate protection solution and appropriate remedies.
