Introduction and agreement.
This website (the “Site”) is owned and operated by Simon 6 Ltd.

PERSONAL DATA
Information about the company that processes your data:
Name: “Simon 6” Ltd.
UIC / BULSTAT: 204914529
Headquarters, address of management and correspondence: Burgas, 1 N: 104 Tsar Simeon Str

Information on the competent data protection supervisory authority
Title: Commission for Personal Data Protection
Headquarters, address of management and correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Telephone: 02 915 3 518
Website: www.cpdp.bg.

Simon 6 Ltd. (hereinafter referred to as “Administrator” or Seaman’s House) operates 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 the data. This information is intended to inform you about all aspects of the processing of your personal data by the Company and the rights you have in connection with this processing.

Grounds for collecting, processing and storing your personal data.
Simon 6 Ltd. collects and processes your personal data in connection with the conclusion and execution of contracts with the Company pursuant to Art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:

– Compliance with a legal obligation that applies to the Administrator;
– For the purposes of the legitimate interests of the Administrator or a third party;
– To create a request to use the services offered by Seaman’s House

Purposes and principles in the collection, processing and storage of your personal data.
When concluding a contract with a commercial partner or a client company, we collect and process personal data on the names of the legal representative of the legal entity – party to the contract, for the purposes of individualization of the party to the contract and its implementation. The contact details of the legal representative or contact officer are official information and as such are not considered personal data.

We follow the following principles when processing your personal data:

– legality, good faith and transparency;
– restriction of processing purposes;
– relevance to the purposes of processing and minimizing the data collected;
– accuracy and timeliness of the data;
– limitation of storage in order to achieve the objectives;
– integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.
When processing and storing personal data, the Administrator may process and store personal data in order to protect the following legitimate interests: fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.

Types of personal data that our company collects, processes and stores.
Simon 6 Ltd. performs the following operations with the personal data provided by you as legal representatives or proxies of legal entities – business partners and customers, for the following purposes:

Concluding and executing a commercial transaction with a counterparty or a contract with a client: For concluding and executing a commercial transaction with a commercial company, we process only the three names of the legal representative or the person authorized by the company.

Conclusion from the impact assessment: Given the small volume of individuals whose data are processed and given the limited amount of personal data that is collected, an impact assessment is not necessary for this operation. The personal data are collected by the Administrator from the persons to whom they also refer from the Commercial Register to the Registry Agency. The administrator does not perform automated data decision making.

Simon 6 Ltd. performs the following operations with the personal data provided by you as persons who made an inquiry through the reservation form on the website of the Company – https://seamanshouse.bg/rezerviraj/:
Processing of inquiries sent through the reservation form on the website https://seamanshouse.bg/rezerviraj/ – the purpose of this operation is to contact the requester by email for the purpose of responding to the requester, identifying the data subject as the requester and sending to response to an inquiry or offer.

Conclusion from the impact assessment: Given the limited scope of the personal data collected, it is not necessary to carry out an impact assessment of the operation. Personal data is collected by the Administrator from the persons to whom they relate. The administrator does not perform automated data decision making.

Term of storage of your personal data.
Simon 6 Ltd. stores the personal data of the legal representatives of legal entities – parties to a contract with the company indefinitely, for the purposes of protecting the legitimate interest of Simon 6 Ltd. and fulfillment of its legal obligations to government agencies and institutions. The Administrator notifies you in case the term for data storage needs to be extended in order to fulfill a regulatory obligation or in view of the legitimate interests of the Administrator or otherwise.

Transfer your personal data for processing.
The controller may, at its discretion, transfer some or all of your personal data to personal data processors for the fulfillment of the processing purposes you have agreed to, subject to the requirements of Regulation (EU) 2016/679 (GDPR). The administrator notifies 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 for the processing of your personal data.
If you do not want all or part of your personal data to continue to be processed by Simon 6 Ltd. for specific or all purposes of processing, you can at any time withdraw your consent to processing by sending a request in free text. The administrator may ask you to verify your identity and the identity of the data subject by asking you to present an identity document on the spot. Withdrawal of consent does not affect the validity of the processing of personal data provided by you until the withdrawal of consent. Simon 6 Ltd. may continue to process part or all of your data if there is a legal obligation for this or for the purposes of protecting its legitimate interests.

Right of access.
You have the right to request and receive confirmation from the Administrator whether personal data related to you are processed. You have the right to access the data related to you, as well as the information related to the collection, processing and storage of your personal data. Upon request, the administrator provides you with a copy of the processed personal data related to you in electronic or other appropriate form. Providing access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in case of repetitive or excessive requests.

Right of correction or completion.
You have the right to ask the Administrator to correct inaccurate personal data related to you or to fill in incomplete personal data related to you.

Right to delete (“to be forgotten”).
You have the right to request the Administrator to delete part or all of the personal data related to you, and the Administrator has the obligation to delete them without undue delay when there is any of the following reasons:

– personal data are no longer needed for the purposes for which they were collected or otherwise processed;
– You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
– You object to the processing of personal data related to you, including for the purposes of direct marketing, and there are no legal grounds for processing to take precedence;
– personal data have been processed illegally;
– personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Controller;
– personal data have been collected in connection with the provision of information society services.

The administrator is not obliged to delete personal data if it stores and processes:

– to exercise the right to freedom of expression and the right to information;
– to comply with a legal obligation requiring processing provided for in EU law or the law of a Member State applicable to the Administrator or for the performance of a task in the public interest or in the exercise of official powers conferred on him;
– for reasons of public interest in the field of public health;
– for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
– for the establishment, exercise or defense of legal claims.

In case of exercising your right to be forgotten, the Company will delete all your data. The data of the legal representatives of commercial companies – partners and clients under contract with the company continue to be stored and processed, despite a request for forgetting, based on compliance with a legal obligation of the company to comply with the legitimate interest and the establishment, exercise or protection of legal claims. In order to exercise your right to be forgotten, you need to send a request in free text and identify yourself with an identity document on the spot.

Right of restriction.
You have the right to ask the Administrator to restrict the processing of data related to you when:

– challenge the accuracy of personal data for a period that allows the Administrator to verify the accuracy of personal data;
– the processing is illegal, but you do not want the personal data to be deleted, but only their use to be restricted;
– The controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or protection of your legal claims;
– You have objected to the processing pending verification of whether the legal grounds of the Administrator take precedence over your interests.

Right of portability.
If you have given your consent for the processing of your personal data or the processing is necessary for the performance of the contract with the Administrator, or if your data is processed in an automated manner, you may, after identifying yourself with the Administrator:

– to ask the Administrator to provide you with your personal data in a readable format and to transfer them to another Administrator;
– to ask the Administrator to directly transfer your personal data to an administrator specified by you, when this is technically feasible.

You can exercise your right of portability by sending a request in free text.

Right to receive information.
You can ask the Administrator to inform you about all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested have been disclosed. The administrator may refuse to provide this information if this would be impossible or would require a disproportionate effort.

Right to object.
You may object at any time to the processing of personal data by the Administrator that relates to you, including if it is processed for profiling or direct marketing purposes.

Your rights in the event of a breach of the security of your personal data. If the Administrator finds a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, he shall notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.

The administrator is not obliged to notify you if:
– has taken appropriate technical and organizational protection measures with regard to the data affected by the security breach;
– has subsequently taken measures to ensure that the infringement does not lead to a high risk to your rights;
– notification would require a disproportionate effort.

Persons to whom your personal data is provided.
For the purposes of processing your personal data and fulfilling the contract, Simon 6 Ltd. may provide your data to third parties – personal data processors who comply with all requirements for legality and security in the processing and storage of your personal data:

Transport and courier companies
Hosting service providers
Marketing agencies
Accounting companies
Other provisions.
In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:

Title: Commission for Personal Data Protection
Headquarters, address of management and correspondence: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2
Telephone: 02 915 3 518
Website: www.cpdp.bg.

Date of publication: 1.09.2021.