General information
As of 25 May 2018, a new "General Data Protection Regulation" - Regulation (EU) 2016/679 or the so-called GDPR (General Data Protection Regulation), adopted by the European Union, comes into force. The regulation aims to ensure the protection of the data of individuals from all EU member states and to unify the regulations for their processing.
As a personal data controller for the provision of intermediary services for the purchase, sale, lease and rental of real estate, Lakshury Investment Ltd. meets all the requirements of the new regulation, collecting only the data of individuals to the extent necessary for the provision of the service and keeping them responsibly and lawfully.
Information about the Data Controller:
Name: "Lakshury Investment" Ltd.
UIC: 206823590
Address. Address: 21, Alexander Brazitsov, A, app 102
MOL: Iskren Todorov
Registered office and registered address. Registered office and registered office. 1407, 1407, "Krustova Vada" Str. 1450, ul. 102
E-mail: office@luxuryinvestment.bg
Phone: +359 899969196
Information on the competent supervisory authority:
Name: Commission for Personal Data Protection
Registered office and registered address. Registered office and registered seat. "1592, Proff. 1592, 1592, 1592, № 2
Correspondence data. 1592 Sofia Blvd. "1592, Proff. No.: 2
Phone:02/915 3518
Email: kzld@government.bg, kzld@cpdp.bg
Website: www.cpdp.bg
"Luxury Investment Ltd. 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 natural persons with regard to the processing of personal data and on the free movement of such data.
Basis for collecting, processing and storing your personal data:
Art. 1. (1) Luxury Investment Ltd. collects and processes your personal data in connection with the provision of intermediary services in the purchase, sale, lease and rental of real estate, for which contracts are concluded with the company on the basis of Art. 1, Regulation (EU) 2016/679, in particular on the basis of the following:
- express consent obtained from you as a customer;
- performance of the obligations of Lakshury Investment Ltd. under its contract with you;
- Compliance with a legal obligation that applies to Luxury Investment.
*For example: under the Anti-Money Laundering Measures Act (AMLA), under which the company is an obliged person;
- For the purposes of the legitimate interest of Luxury Investment Ltd.
(2) Luxury Investment Ltd is the data controller in respect of your data as users of our services. In relation to the personal data that you process using our services, Luxury Investment Ltd acts as a data processor.
Purposes and principles for the collection, processing and storage of your personal data:
Art. 2. (1) Lakshury Investment Ltd collects and processes the personal data that you provide to us in connection with the use of our services and the conclusion of a contract with the company, including for the following purposes:
- creating a customer profile and ensuring full functionality in the provision of our services;
- individualization of a party to the contract;
- accounting purposes;
- statistical purposes;
- securing the performance of the contract for the provision of the relevant service;
- sending information messages, invitations, service change notifications, newsletters with information about properties whose characteristics meet the criteria set by the client, etc.
- improve and personalise the service by offering you relevant offers, events and other products and services that may be of interest to you;
(2) Lakshury Investment EOOD complies with the following principles when processing your personal data:
- legality, fairness and transparency;
- limitation of the purposes of processing;
- relevance to the purposes of the processing and minimisation of the data collected;
- data accuracy and timeliness;
- limitation of storage to achieve the objectives;
- integrity and confidentiality of processing, and ensuring an appropriate level of security of personal data.
(3) In processing and storing personal data, Lakshury Investment Ltd may process and store personal data in order to protect its legitimate interests:
- performance of its obligations to the National Revenue Agency, the Ministry of the Interior, the State Police and other state and municipal authorities.
What types of personal data does Luxury Investment collect, process and store?
Art. 3. (1) Lakshury Investment EOOD shall carry out the following operations with personal data for the following purposes:
- Registration of a client profile for the provision of a real estate intermediary service. The purpose of this operation is to create a profile to be associated with the service used, adding information about the searches and offers of the persons to the client profile. Conclusion of the impact assessment: On the basis of the above mentioned impact assessment, the Data Protection Officer considers that the operation 'Conclusion of a contract for an intermediary service' is admissible to carry out and provides sufficient guarantees to protect the rights and legitimate interests of data subjects in accordance with the requirements of the GDPR.
- Conclusion and execution of a commercial transaction with a customer or partner - the purpose of this operation is the conclusion and execution of a contract with a commercial partner or customer and its administration;
- Sending of information messages - the purpose of this activity is to administer the process of sending messages to clients concerning changes in services, terms, thresholds and obligations, non-performance, according to the intermediary service contract.
- Newsletter mailing- the purpose of this operation is to administer the process of sending newsletters to customers who have indicated that they wish to receive them;
(2) Luxury Investment Ltd processes the following categories of personal data and information for the following purposes and on the following grounds:
A/ Data: your personal data (first and last name, personal identification number or place and date of birth for foreign citizens, data and/or copy of identity document, postal address, e-mail and telephone number)
B/ Purposes for which the data is collected:
1) Customer registration;
2) Contacting the customer and sending information to the customer, including - if requested - sending newsletters and advertising messages;
(3) Luxury Investment Ltd. does not collect or process personal data relating to the following:
- reveal racial or ethnic origin;
- reveal political, religious or philosophical beliefs, or trade union membership;
- genetic and biometric data, health data or data on sex life or sexual orientation.
(4) The Company shall not carry out automated decision-making with data.
Storage period of your personal data:
Art. 4. (1) Lakshury Investment Ltd shall store your personal data for a period no longer than the existence of the contractual relationship with the company. After the expiration of this period, Lakshury Investment Ltd shall take the necessary care to delete and destroy all your data without undue delay.
(2) Lakshury Investment Ltd. will notify you if the data storage period needs to be extended in order to fulfil the purposes, fulfil the contract, for the legitimate interests of Lakshury Investment Ltd. or otherwise.
(3) Lakshury Investment Ltd shall retain the personal data that it is required to retain under applicable law for the relevant period provided for, which may exceed the duration of your registration.
Transfer of your personal data for processing:
Art. 5. (1) Luxury Investment Ltd may, at its own discretion, transfer some or all of your personal data to processors for the purposes of processing, subject to the requirements of Regulation (EU) 2016/679.
(2) Luxury Investment Ltd shall notify you in the event of an intention to transfer some 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 wish all or part of your personal data to continue to be processed by Lakshury Investment Ltd. for any or all of the processing purposes, you may withdraw your consent to processing at any time by completing the "Notice of withdrawal of exercise of rights in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 1, Article 12(4)."
(2) Luxury Investment Ltd may ask you to verify your identity and identity with the person to whom the data relates.
Right of access
Art. 7. (1) You have the right to request and obtain confirmation from Luxury Investment Ltd as to whether personal data relating to you is being processed.
(2) You have the right to access the data relating to it and the information concerning the collection, processing and storage of your personal data.
(3) Luxury Investment Ltd. shall provide you, upon request, with a copy of the processed personal data relating to you in electronic or other appropriate form, on the basis of "Request for confirmation and access to processed personal data, in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 15."
Right of correction or completion
Art. 8. You may correct or complete inaccurate or incomplete personal data relating to you by completing and sending to us a "Request for rectification of personal data processed in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 16."
Right to erasure ("being forgotten")
Art. 9.(1) You have the right to request from Luxury Investment Ltd. the deletion of the personal data relating to you, and Luxury Investment Ltd. has the obligation to delete them without undue delay where one of the following grounds applies:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- You withdraw your consent on which the processing 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 legitimate grounds for the processing that override;
- personal data have been unlawfully processed;
- personal data must be erased in order to comply with a legal obligation under EU or Member State law that applies to Luxury Investment Estates;
(2) Luxury Investment Ltd. is not obliged to delete personal data if it stores and processes them:
- to exercise the right to freedom of expression and the right to information;
- to comply with a legal obligation requiring processing under EU or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
- for public health reasons;
- for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
- for the establishment, exercise or defence of legal claims.
(3) In order to exercise your right to be "forgotten", you should submit a "Request for erasure of personal data processed in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 17."
(4) Lakshury Investment Ltd. shall not delete the data which it has a legal obligation to store, including for the purpose of defending legal claims made against it or proving its rights.
Right to restriction
Art. 10. You have the right to request that Lakshury Investment Ltd. restrict the processing of data relating to you by means of a "Request for restriction of processing of personal data in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 18" when:
- challenge the accuracy of the personal data, for a period that allows Luxury Investment Ltd to verify the accuracy of the personal data;
- the processing is unlawful, but you do not want your personal data to be erased, but only for its use to be restricted;
- "Luxury Investment Ltd no longer needs the personal data for processing purposes, but you require it for the establishment, exercise or defence of your legal claims;
- You have objected to the processing pending verification whether the legitimate grounds of Luxury Investment Ltd override your interests.
Right to portability
Art. 11. (1) You may at any time retrieve the data stored and processed about you in connection with the use of the services of Luxury Investment by submitting to us a "Request for transfer or transfer of processed personal data in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 20."
(2) You may request that Luxury Investment Ltd directly transfers your personal data to a controller designated by you where this is technically feasible.
Right to receive information
Art. 12. You may request that Luxury Investment Ltd. informs you of any recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested has been disclosed by sending us a "Request for notification upon rectification, erasure or restriction of processing of personal data, in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 19". "Luxury Investment Ltd may refuse to provide this information if it would be impossible or would require a disproportionate effort.
Right to object
Art. 13. You may object at any time to the processing of personal data concerning you by Luxury Investment, including if it is processed for profiling or direct marketing purposes, by sending us an "Objection to the processing of personal data in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 21."
Your rights in the event of a personal data breach
Art. 14. (1) If Luxury Investment Ltd. identifies a breach of security of your personal data that may pose a high risk to your rights and freedoms, we shall notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken, by means of a "Personal Data Breach Notification in accordance with Regulation (EU) No 2016/679 of 27 April 2016, Section 2, Article 33(1)."
(2) Lakshury Investment Ltd is not obliged to notify you if:
- has taken appropriate technical and organisational measures to protect the data affected by the security breach;
- has subsequently taken measures to ensure that the infringement will not result in a high risk to your rights;
- notification would require a disproportionate effort.
Persons to whom your personal data is provided
Art. 15. For keeping the company's accounts, in accordance with the legal requirements in the Republic of Bulgaria, in case of inquiries by the NRA, GDPR and other competent authorities, for statistical purposes and other cases not contrary to the Regulation.
Art. 16. The controller does not transfer your data to third countries.
Other provisions
Art. 17. In the event of a violation of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission, whose correspondence details are indicated above.
Art. 18. You can exercise all your rights regarding the protection of your personal data using the forms attached to this information. Of course, these forms are optional and you may make your requests in any form that contains a statement to that effect and identifies you as the data holder.
Art. 19. If the consent relates to a transfer, the Controller shall describe the possible risks of the transfer of the data to third countries in the absence of an adequate protection solution and appropriate means of protection.
Art. 20. Where you instruct Luxury Investment Ltd to process personal data of a third party for the purposes of using the service, Luxury Investment Ltd shall act as the processor of the personal data.
Last update date: 21.09.2024