Last Updated: May 25, 2018
I. WHO WE ARE
The Company offering services through this website as an Administrator of personal date, is VIP TRAVEL PARTNER LTD., IDN 202436482, with management seat and address of management: Republic of Bulgaria, Sofia, region of Nadejda, residential complex Svoboda, 22, Nikola Jekov Str., floor 4, apt.4.9, represented by the manager Nikolay Hristov.
Responsible Employee for Data Protection in the Company: Nikolay Hristov email: [email protected] , tel: +359 895038709
VIP TRAVEL PARTNER Ltd will treat the Client’s personal information as strictly confidential. We respect your right of privacy and therefore work continuously to protect the personal data that we process observing the principle of minimization and permanent protection optimization.
The Company undertakes to:
- Take appropriate technical and organizational measures to ensure that your personal information is kept secure and is protected against unauthorized or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
- Promptly notify the Client if it becomes aware of any unauthorized use, disclosure or processing of his/her personal information;
- Provide the Client with reasonable evidence of its compliance with its obligations under this policy on reasonable request;
- Upon the Client’s request, promptly return or destroy any and all of his/her personal information in its possession or control.
II. INFORMATION WE COLLECT
We collect only personal data which are necessary for pursuing our business and process personal data only by legal means. We do not sell or disseminate your personal data in any other way.
There are two general categories of information we collect.
2.1 Information you give to us.
We ask for and collect the following personal information about you when you use the VIP TRAVEL PARTNER website:
Contact form. When you fill in our contact form, we require certain information such as your first name, last name and email address, and any other information that users may decide to provide to the Company through the contact form.
Your e-mail address is necessary to enable us to contact you in response to your inquiries by providing the requested information or assistance you may demand.
We would like also to use your e-mail address for the purpose of providing information about our services, promotions, discounts and bonuses of which you can take advantage only providing that you give your explicit consent to receive our newsletter.
You can withdraw your consent for receipt of such information at any time by contacting the employee responsible for Data Protection in the Company by mail, e-mail or on paper in our office.
We undertake not to use your contacts for marketing or advertising of third parties’ goods and services.
The information which is necessary for the conclusion and adequate performance of the contract between you and us shall be collected by e-mail or mail. At the time of provision of additional personal information you will be asked to sign particular forms for agreement to allow us to comply with our legal obligations regarding the collection and process of personal data. Without it, we may not be able to provide you with all the requested services.
2.2 Information we automatically collect from your use of the VIP TRAVEL PARTNER website.
III. TERM FOR RETENTION AND ERASION OF PERSONAL DATA
In general we process data until the Client uses our services. The Company will not retain the Client’s personal information longer than the period for which it is necessary for the achievement of its legitimate purposes.
IV. METHOD FOR DATA COLLECTION
We process and use only data provided by clients voluntarily. The Client undertakes to provide accurate and current information, and not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent his/her affiliation with anyone or anything.
Therefore, the client shall be personally liable for provision of personal data of third parties without their consent and/or knowledge in compliance with the applicable laws, including personal data of individuals who are legal representatives of entities.
VIP TRAVEL PARTNER Ltd offers services and allows use of this website only by persons over the age of 18 years. If you are under 18 years, please, recourse to the assistance of an adult to avail of our services. If we receive information that we have collected them data of a person under 18 years, we are going to erase them immediately unless the Company is legally obliged to store such data.
VI. SHARING & DISCLOSURE
6.1. VIP TRAVEL PARTNER Ltd may share your information, including personal information only where you have provided consent, as described at the time of consent,
6.2. VIP TRAVEL PARTNER Ltd shall be entitled to disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against VIP TRAVEL PARTNER Ltd, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to protect the rights, property or personal safety of VIP TRAVEL PARTNER Ltd., its employees or members of the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the VIP TRAVEL PARTNER Ltd.’s website secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we may notify our clients about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon VIP TRAVEL PARTNER Ltd’s property. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
6.3. Service Providers.
VIP TRAVEL PARTNER Ltd shall be entitled to disclose your information for the purposes of distributing same to various employees and/or partners who assist VIP TRAVEL PARTNER Ltd in providing services and thus need to know the Client’s personal information in order to render a proper and efficient service to him/her. These third parties have limited access to your information to perform their tasks on our behalf. We will ensure that all such employees and/or partners service providers having access to the Client’s personal information are bound by appropriate and legally binding confidentiality and non-use obligations in relation to his/her personal information.
After the conclusion of a particular contract for our services we will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you for which a respective agreement on your side will be required.
VII. Business Transfers.
VIII. Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
IX. YOUR RIGHTS
You may exercise any of the rights described in this section by sending an email to the Responsible Employee for Data Protection on [email protected] . Please note that we may ask you to verify your identity before taking further action on your request.
9.1. Right of confirmation
You have the right to ask for confirmation whether we process data relating to you, or to ask for copies of your personal information held by us or for information relating to the collection, processing and storage of your personal data.
9.2. Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
9.3 Data Access and Portability.
You may request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
9.4 Data Retention and Erasure.
If you no longer want us to use your information, you can request that we erase your personal information.
- Please note that if you request the erasure of your personal information:We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations.
9.5 Withdrawing of Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by VIP TRAVEL PARTNER Ltd. you may withdraw your consent at any time by sending a communication to VIP TRAVEL PARTNER Ltd. specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
You have also the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 9.6 and pending the verification whether the legitimate grounds of VIP TRAVEL PARTNER Ltd. override your own.
9.6 Objection to Processing.
You are entitled to require VIP TRAVEL PARTNER Ltd. not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing VIP TRAVEL PARTNER Ltd. will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
1.Please, consider that your requests are unfounded or excessive, we shall be authorized to:impose a fee taking into account the administrative costs we would incur to provide or communicate the requested information or to pursue the requested actions;
2.decline the requested action.
We shall exert all reasonable efforts to honour your request within 30 days as from its receipt. If necessary, this term shall be extended by no more than two months depending on the complexity and number of your requests.
X. LODGING COMPLAINTS.
The competent authority for the Republic of Bulgaria is the COMMISSION FOR PERSONAL DATA PROTECTION.
Address for correspondence: 1592 Sofia, 2, Tzvetan Lazarov Blvd.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are data encryption and information access controls.
Whilst the Company is of intent to take reasonable measures to keep personal information about the Client confidential, it shall however not be liable for any loss or damage, suffered as a result of the disclosure of such information beyond the reasonable control of the Company.