The policy was developed by ULEN AD, UIC 101156430, with address in Bansko 2770, 94 Pirin Str. - in its capacity of Personal Data Administrator.
According to Regulation (EU) 2016/679, personal data is any information by which an individual can be identified. As personal data should be considered the name, identification number, location, online identifier or one or more characteristics specific to the physical, physiological, genetic, mental, intellectual, economic, cultural or social identity of a particular individual. In this policy, personal data means any information about you, such as your names, date of birth, PIN / LNCh (Personal No.), your personal identification number; postal address, identity document number (identity card, passport), photo, e-mail address, telephone number, information about your participation in the Loyal Customers Program, providing you with various privileges, information about your participation in games organized by us and other data you have provided to us when using the services we offer and through which you can be uniquely identified.
How do we receive your personal data?
Ulen AD, in its capacity of Administrator, collects and processes personal data at each contact with clients in the process of providing various types of services in its activity. We strive for ensuring a lawful, fair and transparent processing of personal data for specific, explicitly stated legitimate purposes in this policy, respecting the principles of "data minimization", "accuracy", "storage limitation", "integrity and confidentiality ”and“ reporting ”.
Personal data processing is carried out in the presence of any of the following causes:
1. The processing is necessary for the contract performance to which the data subject is a party or for taking steps at the request of the data subject before execution of a contract.
2. The processing is necessary for the observance of a legal obligation, which is applied in respect of Ulen AD, in its capacity of personal data administrator.
3. The data subject has agreed to the processing of his or her personal data for one or more particular 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.
4. Processing is necessary for the purposes of the legitimate interests of the administrator.
We aspire to establish and sustain responsible trade relations, to provide quality and timely services tailored to your preferences and needs, and in this regard we may ask you for additional information in order to improve the quality of services. We process some of the collected personal data in order to maintain records of the services and products we provide to you, by analyzing the services used so that we can manage them effectively and plan our development. ULEN AD offers targeted discounts for certain age categories, by using which it is necessary to record your date of birth or document number certifying the conditions entitling the person to purchase the relevant category of service in order to comply with the requirements of accounting and tax legislation, we need to check your ID or other relevant documents, which certify the fulfilling of the conditions.
The information provided by you may be used to send you useful information about special offers, promotional initiatives and new products and services, some of which may be shared with other organizations. In this case, your personal data will be used only with your explicit consent.
In an effort to create a safe and secure environment for tourists in the Ski Center, we may use some of the personal data collected, including the installed video surveillance system to detect and prevent fraud, theft and other troublesome activities. In some cases we may need to use your information to process and resolve legal disputes, to apply the rules for using the service "rental of ski equipment" or "ski/snowboard school", to comply with the rules established in the Ski Center and the General Terms and Conditions which you can get acquainted with HERE / or for fulfillment of lawful requests by a law enforcement body or jurisdiction.
Some of the services we offer also include services under our affiliate programs provided by third parties. If you participate in such a package or service, your personal information will be shared with that third-party only after receiving your explicit consent and to the extent necessary to provide that service and process the request.
The categories of personal data we process and the purposes for which they are processed?
We process your personal data in the process of providing equipment for rent from the ski lockers we manage. The types of personal data that are collected when using the service "rental of ski equipment" are: names, date of birth; address; place of accommodation; telephone or e-mail for contact with the person; weight; height, age; gender; skiing skills, boot size, boot sole lenght/mm/ as the purposes of processing are: take step to entering into a contract for rental of ski/snowboard equipment; fulfillment of the rights and obligations arising from the concluded rental contract; protection of the health and life of the clients by providing appropriate safe equipment in accordance with the provided by the individual personal data; payment for a certain category of service, determined by the age and/or height of the client; legal obligation arising from tax legislation; receiving information and / or offers, with the express consent of the person; legitimate interest of the company and providing quality service. You can get acquainted with the General rules and conditions for renting ski / snowboard equipment from the ski wardrobes managed by Ulen AD here.
Your personal data is also received by us when purchasing and using lift passes from Ulen cash desks, from our partners or online via the Ski Point, the "Bansko ski" mobile platform and the kiosks. The types of personal data that are processed in this process are: names; a photograph, date of birth or number of a document certifying the conditions entitling the person to purchase the respective lift passcategory; telephone or e-mail for contact with the person; data on the payment made, as the purposes of processing are as follows: person’s identity; registration of the person in the platform "Ski point" and the "Bansko ski" App; possibility for feedback with him in the process of request processing, including for restoring access to the person's profile in a mobile platform and the App, in case of a forgotten password; take steps to entering into a contract for provision of service - activation of a lift pass, ensuring the use of a lift facilities in the Ski Center Bansko; fulfillment of obligations under a service contract; prevention of unregulated use of lift passes in violation of the approved General Rules; purchase of a certain card category, determined by the age of the person; registration in the Loyalty Program, providing privileges for its members, with the express consent of the person; notifying the members of the Bansko Loyalty Club about upcoming events and / or privileges included in the Program, related to their rights; using services under our partnership programs and receiving information and / or offers related to these partnerships, with the express consent of the person; legal obligations/rightarisings from bulgarian legislation/tax legislation and Ordinance on safety and information security of ski runs and others/ including ensuring public order; legitimate interest of the company; providing quality service and analysis. The user may receive commercial messages, news, offers and contacts if he has accepted his data to be used for direct marketing. Unsolicited information for marketing purposes may also be sent to the e-mail address specified by him, and the User shall be clearly and unambiguously informed about the nature of the message.
Some of the personal data is necessary to acquaint you with the conditions for participation in the Loyalty Program and the privileges it provides you. Participation in the Bansko Loyalty Club, which is aimed at those winter sports fans who buy season passess, will give you the opportunity to receive a special personalization of the services provided, according to the type of pass you have. In order to join the Program, it is necessary to meet the conditions set by the company and to provide a limited amount of additional personal data that will allow us to provide you with designated services and participation in individual events. By enrolling in the Program, you confirm your desire to participate in it, agree with the announced General Terms and Conditions, which determine the possible use of your personal data, give your explicit consent to use the email you specify for explicit purposes.
We process your personal data in case of an inquiry made by you and a booking made for accommodation, both in place and through registration in the specialized tourist platforms (Booking, etc.). The personal data provided in this process, such as: names / in Cyrillic for Bulgarians, in Latin for foreigners; PIN/LNCh (Personal No.); date of birth, sex; citizenship; ID card number or valid national identity document; the state that issued the identity document; address; contact information with the person, information related to the reservation itself and the payment of the stay are necessary in order to: identify the person; possibility for feedback with him in the process of processing the booking request; contractual relations in connection with the provision of tourist services / accommodation of clients; fulfillment of a legal obligation / under the Tourism Act, the Law on Foreigners in the Republic of Bulgaria (LFRB); providing a better service tailored to your preferences.
Clients’ personal data are processed when sending a request or registration for participation in games announced on our website http://www.banskoski.com. The categories of personal data that are processed are: two or three names / depending on the game /, e-mail address, phone number; date of birth, PIN and valid postal address, ID number, date of issue, issuing authority and validity required for: registration of the person to participate in the game, feedback to restore access to the person's profile, if forgotten by him password; identification of the person, both for participation in the game and for winning and subsequent obtaining of the prize; feedback with the person when winning a prize from the Campaign and taxation of the prize obtained, according to the Bulgarian legislation. The processing of the specified personal data is necessary for participation in the games, whereas the participants give their explicit consent the personal data provided by them to be processed for the purposes abovementioned.
You can get acquainted with this policy HERE. We recommend that you do so before using the Bansko Ski mobile app.
When processing your personal data, we abide by the following principles:
1. Your personal data will only be processed for the above purposes. A change in the purposes of processing can only occur with your explicit consent.
2. Your personal data is protected by appropriate technical and organizational security measures, including when interacting with third parties.
3. We do our best to keep your personal information up to date for the purposes set out above.
4. Your personal data is processed only as long as it is necessary to achieve the above stated goals, after which it will be reliably deleted, unless there are regulatory requirements or legitimate interests to be stored for certain periods.
5. We will respect your rights in regard to the protection of your personal data and will satisfy any of your requests in this respect within the period fixed by the law.
6. When we need to share your data with third parties in order to provide you with the services and products requested by you, we will require compliance with the rules set forth in this Policy and in the personal data management organization developed and implemented in ULEN AD.
7. We observe the restrictions for processing personal data of persons under 16 years of age, receiveed in the conditions of the information society, as well as sensitive personal data.
8. We will make every effort to inform you in a timely manner, if we receive your personal data from third-party partners, suppliers or other business sources.
9. Your personal data is processed in compliance with the 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.
10. We will make every effort to respond to any of your inquiries regarding the processing of your personal data 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 you and provide you with a written response not later than 30 days after receiving the request.
Who do we share your data with?
Your personal data may be shared with our partner companies, which can inform you in the form of commercial messages about other services they provide. Such messages will be sent only with the prior consent of the User, which he may cancel at any time. In some cases, unsolicited commercial messages may be sent, in compliance with the law, to the e-mail address provided by the User.
In all other cases, we will process, disclose or share your personal data only if required by the law or when required in order to comply with the requirements of public authorities acting under legal jurisdiction.
Where do we store and how do we process your personal data?
Your personal data is stored electronically on our servers, which are located in a controlled environment with a high level of information security. We take the possible organizational and technical measures for data protection, 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 motivated by our desire to strictly adhere to the requirements of REGULATION (EU) 2016/679 and the Personal Data Protection Act (PDPA). It introduces rules for data processing, both for our customers and for our employees and representatives of the organizations we partner with to achieve 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 your 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 receive access to the personal data of our customers and employees.
Your rights 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 agreed 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 the received answer does not satisfy you, 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 where applicable. 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.