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PRIVACY POLICY

„BANSKO SKI” MOBILE APPLICATION

At ULEN AD we understand the responsibility we bear for your personal data and strive for complying with high standards for the protection of personal information and privacy. We collect, store and process your personal data only to the extent necessary for the conduct of our business, with clearly defined objectives and compliance with the requirements of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals in connection with the processing of personal data and on the free movement of such data (hereinafter the ‘’Regulation’’) and the Personal Data Protection Act (PDPA).

1. PURPOSE AND SCOPE

This privacy policy applies only to the mobile application "Bansko Ski" (the „Application“) of "ULEN" AD (the Company, We) and aims to inform the Users of the Application about the responsible and lawful manner in which the Company processes their personal data, provided by them when using the service of recharging / recharging of lift passes online, as well as access to useful information about the Ski Center Bansko, including information about the weather / weather in the ski center, the working slopes and facilities, access to a picture of real-time cameras and information on the use of a ski pass by customers of the ski center.

The policy also specifies the rights of the Users as personal data entities arising from the Regulation and the applicable national legislation determining the procedure for personal data processing.

The policy was developed and published by ULEN AD, UIC 101156430, with an address in Bansko 2770, 94 Pirin Str. - in its capacity of Personal Data Administrator.

For all other cases and circumstances, when personal data of users of the tourist services provided on the territory of Ski Center Bansko are processed, the conditions set out in the general Privacy Policy apply, which can be seen on the website of ULEN AD https: // www.banskoski.com

General Terms and Conditions (GT&Cs) for Bansko Ski Application usage have been developed by the Company. These rules can be seen HERE as well accessed via the Application.

We recommend all users of the Bansko Ski mobile application to get acquainted with the current policy and the General Terms and Conditions before using the Application.

2. THE CATEGORIES OF PERSONAL DATA WE PROCESS AND THE PURPOSES FOR WHICH THEY ARE PROCESSED

For the purposes of this policy, personal data means only personal information provided by the Users when using the Application, which can uniquely identify them as individuals, namely: first name and surname; date of birth; e-mail; lift pass number (at the discretion of the user, depending on the purpose for which the application will be used, it is necessary for charging or recharging a lift pass), photo when charging and recharging lift passes (at the request and discretion of the User, providing this data is optional).

The purposes of personal data processing provided upon registration in the Application are as follows:

- identification of the User as as an individual using a certain, personally provided online paid and / or free service;

- providing an opportunity for feedback to the User in the process of processing the request for providing a paid online service - charging / recharging a ski / lift pass for the use of lift facilities in the Ski Zone with center in the town of Bansko;

- providing access to useful information about the activities carried out in the Ski Zone with center in the town of Bansko;

3. GROUNDS FOR PERSONAL DATA PROCESSING.

Personal data processing is carried out if there is any of the following grounds:

3.1. To perform a contract, to which the data subject is a party or to take steps at the request of the data subject before signing a contract.

The personal data provided by the Users, limited in type and volume, Ulen AD collects and processes in its capacity as a Provider of the specific service and access to useful information offered through Bansko Ski online. The data is needed to create a user profile (registration) in the Application. The creation of a user profile is accepted as a form of contract between the Provider and the User and takes effect from the moment of activating the user profile. The confirmation of the registration is an electronic statement within the meaning of the Electronic Document and Electronic Signature Act, by which the User declares that he wishes to use the services provided electronically.

3.2. When processing is necessary to comply with a legal obligation.

ULEN AD offers targeted discounts for certain age categories, when using which it is necessary to reflect the date of birth in order to certify the right of the person to receive the specific service.

This is necessary to ensure compliance with the requirements of accounting and tax legislation when paying for and using the service.

3.3. When the data subject has consented to the processing of his personal data for one or more specific purposes. In cases where personal data are processed only on the basis of a given consent, the data subject has the right to withdraw his consent at any time, except in cases where the processing of data is also based on item 1 and / or item 2, mentioned above.

This ground is also valid for Ulen AD. The information provided by Users can be used to send them useful information about special offers, promotional initiatives and new products and services, some of which can be presented together with other organizations. In this case, the personal data will be used only with the explicit consent of the User.

3.4. When processing is necessary for the purposes of the legitimate interests of the administrator.

We at Ulen AD strive to establish and maintain responsible trade relations, to provide quality and timely services in accordance with the preferences of users. In this regard, we can ask them for additional information in order to improve the quality of services.

We process some of the collected personal data in order to maintain accountability for the service we provide, analyzing its use so that we can manage it effectively and plan our development.

In an effort to create a safe and secure environment in the ski area, we may use some of the personal data collected to detect and prevent fraud, consumer misconduct and other unwanted activities.

In some cases, we may need to use the personal information provided during registration to resolve legal disputes related to the application of the General Terms and Conditions (GT&Cs) for the use of the Application or to comply with lawful requests from law enforcement authority.

4. IN PERSONAL DATA PROCESSING, WE FOLLOW THE PRINCIPLES BELOW:

4.1. Personal data of the Users of the Application are processed only for the above purposes. A change in the processing purposes can only occur with the consent of the data subject.

4.2. The processed personal data is protected by appropriate technical and organizational security measures, including when interacting with third parties.

4.3. We make every effort to keep the personal data processed up-to-date for the purposes set out above.

4.4. Personal data are processed only as long as they are necessary to achieve the above objectives, after which they will be deleted in a reliable manner, unless there are regulatory requirements or legitimate interests to be stored for certain periods.

4.5. We respect the rights for protection of personal data and will satisfy within the statutory period any request of the Users in this regard.

4.6. When we need to share personal data of Users with third parties in order to provide the requested service, we will require compliance with the rules set forth in this Policy and in the organization developed and implemented in ULEN AD for personal data management.

4.7. We will make every effort to inform Users in a timely manner, if we receive their personal data from third party partners, suppliers or other business sources.

4.8. Personal data is processed in compliance with applicable legal and regulatory requirements, in terms of transparency and professional correctness. We do not collect or process sensitive personal information, such as race, religion, political affiliation, or union affiliation. The Application (and in the Company in general) does not collect and process specific features specific to the physiological, genetic, mental, intellectual, economic, cultural or social identity of the individual User as a specific individual. We do not use the personal data provided by Users for profiling or for automated decision making.

4.9. We will make every effort to respond to any inquiries regarding the processing of personal data of Users within 14 days. If the collection of the necessary data for the preparation of a response requires the commitment of a substantial resource on our part, we will promptly inform the data subject and provide a written response not later than 30 days after receipt of the request.

5. WITH WHOM WE SHARE PERSONAL DATA OF USERS

5.1. The technology of the service for charging / recharging of ski passes offered via the Application in the processing and storage of the personal data of the Users requires the participation of third parties hired by Ulen AD - specialized companies, providers of IT and communication services. In such cases, the personal data of the Users will be processed under controlled conditions, only to the extent strictly necessary for the provision of the service. The companies providing IT services are fully aware of the requirements of REGULATION (EU) 2016/679 for personal data protection and are committed to comply with the terms of our Privacy Policy. Ulen AD maintains lasting contractual relations with these companies. If necessary, the requirements for the lawful processing of personal data may be formulated in agreements between Ulen AD, as a Personal Data Administrator and the companies - suppliers, as Personal Data Processors.

5.2. Personal data of the Users can be shared with our partner companies in order to inform you in the form of commercial messages about other services provided by them. Such messages will be sent only with the prior consent of the User, which may be canceled at any time. In some cases, unsolicited commercial messages may be sent to the e-mail address provided by the User in compliance with the law.

In all other cases, we will process, disclose or share personal data only if required by law or when required in order to comply with and comply with the requirements of public authorities acting under legal jurisdiction.

6. COOKIE POLICY

You need to know that when registering in the Application, you, as Users, will be recognized by the so-called “Cookies’’ that are used everywhere on the Internet. Further information on what cookies are and how you can manage their use can be found in our Cookie Policy HERE.

7. WHERE DO WE STORE AND HOW DO WE PROCESS PERSONAL DATA?

The personal data of the Users are stored in electronic form on our servers, which are located in a controlled environment with a high level of information security. The possible organizational and technical measures for data protection are taken, applying the established good practices and the requirements of the information security standards.

A documented system for management and protection of personal data has been developed and implemented in Ulen AD. The implementation of this system is dictated by our desire to strictly adhere to the requirements of REGULATION (EU) 2016/679 and the Personal Data Protection Law). It introduces rules for data processing, both for our customers and our employees and representatives of the organizations we partner with for achieving the goals that require personal data processing. The system of personal data protection contains the guidelines of the established good practices and the requirements of the international standards for information security. Our employees are trained to comply with the requirements of the implemented system. Access to personal data is based on the principle of "need to know" in accordance with the functional obligations of our staff and that of our partner organizations. Where necessary, we have signed agreements defining the responsibilities and obligations of ULEN AD and that part of our partners / contractors who can access the personal data of the Users of the Application.

Through the Application, Users can access links to third party websites. If they provide their personal information on these sites, they should comply with the fact that the Privacy Policy of these sites applies. Ulen AD is not responsible for the collection and processing of personal data by these third parties.

8. THE RIGHTS OF THE USERS – YOUR RIGHTS

The rights of the users as a data subject are set out in Art. 12-23 of Regulation 2016/679 and include the right to receive information and access; to correct and delete personal data (right to be "forgotten"); to limit processing; for data portability at your request to another administrator, as well as the right to object to the data processing.

You also have the right to receive confirmation that your personal data is being processed; information for the purposes of processing; information about the categories of processed personal data; information about the processing time; information about who they are shared with, as well as receive a copy of your processed personal data.

If you have given consent to the processing of your personal data and decide for any reason to withdraw it, we will delete the processed data, unless there is a regulatory requirement or legitimate interest in its storage for a certain period.

If you have any questions regarding our Privacy Policy or in connection with your rights regarding the processed personal data, you can contact the Data Protection Officer at ULEN AD by e-mail: dpo.banskoski@gmail.com or write to us at address: Blagoevgrad region, Bansko Municipality, 2770 Bansko, 94 Pirin Street.

If you are not satisfied with the answer received, or you consider that there is a violation of your data protection rights in connection with the processing of your personal data by ULEN AD, you can file a complaint to the Commission for Personal Data Protection at the following contacts: Sofia 1592 , 2 Prof. Tsvetan Lazarov Blvd., https://www.cpdp.bg and / or other supervisory / regulatory body.

This Policy is subject to update if necessary. The current version will be at your disposal immediately after the introduction of an amendment, and on this occasion we invite you to periodically review it.

Contacts:

Ulen AD; town of Bansko 2770

phone +359 749 84480

Emergency numbers

Police 112

Emergency number 112

Rescue Service 1471