PRIVACY POLICY AND PROTECTION OF PERSONAL DATA PROCESSED BY COMPANY FOR INTERNATIONAL MEETINGS LTD. DURING AND IN REGARD OF PROVIDING TOURIST AND CONGRESS SERVICES


Company for International Meetings Ltd. respects its clients personal life’s inviolability and guarantees maximum protection of their personal data processed during and in regard of providing tourist and congress services and other connected activities. This Privacy Policy is based on requirements of 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, and repealing Directive 95/46/EC (“Regulation (EU) 2016/679”). All amendments to Privacy Policy will be applied after its current contents on our website: www.cim.bg Privacy Policy will be applicable to your personal data if you are a natural person or a representative of a juridical person using or wishing to use Company for International Meetings Ltd. services.  
 
1. Who processes your personal data and is responsible for them? 
Company for International Meetings Ltd. is a trade company registered under Commercial Law in the Trade Register in the Registry Agency with Unified Identification Code of 040909871. The Company gathers, processes and preserves your personal data under this Policy’s conditions. Company for International Meetings Ltd. was entered into National Tourist Register of the ministry of Tourism as an enterprise providing a wide range of touristic services. Company for International Meetings Ltd. was entered into Tour Operators and Agents Public Register under Registration Order No. РД 16 – 47/28.01.2005. Company for International Meetings Ltd. is an administrator of personal data under Regulation (ЕU) 2016/679 and Personal Data Protection Law. You can contact us on our management address: City of Sofia 1000, 18 Hristo Belchev Street or filling in the electronic contact form on our website: https://www.cim.bg/. You can address all issues regarding your personal data processing to Company for International Meetings Ltd. official responsible on Personal Data Protection on e-mail: cim@cim.bg; Tel. + 359 2 980 3618 
 
2. What data do we process, for what purposes and on what legal grounds? 
2.1. Depending on particular purposes and grounds Company for International Meetings Ltd. processes the following data individually or in combination: 
А) The data you have provided for identification and contract obligation performance of both Company for International Meetings Ltd. and its client:
  • Full names, ID or Personal Number of the client, his/her/its contact address, phone and/or electronic address, or a contact person appointed by you; 
  • Full names, ID Number, contact address, and other data of your authorized representative, stated in the document you have authorized him with to represent you in front of Company for International Meetings Ltd.; 
  • Full names, ID Number, contact address, and other data of your legal representative; 
  • Full names, ID Number, contact address, and other data of the persons stipulated as juridical persons’ contact persons; 
  • Full names, ID Number, contact address and other data of persons stipulated to receive invoices; 
  • ID document’s number, issuing and expiry date and issuing body; 
  • Data gathered for payment made by Company for International Meetings Ltd.: Credit or Debit Card number, bank account, and other bank and payment information gathered and processed in regard of bank payments; 
  • Data about services you use from Company for International Meetings Ltd.’s portfolio; 
  • Information about your household, marital status, demographic information, and other data you provide when you take part in our research voluntarily, or other feedback you give us regarding products and services you use and preferences you express for the services we provide.
 
B) Data created or generated by Company for International Meetings Ltd. during services providing process: 
  • detailed reports coming together with monthly bills/invoices and the amounts of due payments contained in them; 
  • voice recordings of telephone conversations initiated by our operator in the contact center when we offer services;
  • video recording or photo made in compliance with preliminarily announced seasonal or promotion campaigns organized by Company for International Meetings Ltd. addressing unlimited number of people; 
  • information about the type and contents of a contract, as well as any other information regarding the contract, including e-mails, letters, troubleshooting orders, complaints, applications, appeals or any other feedback received from you; 
  • Data claims regarding Company for International Meetings Ltd.’s service; 
  • Data on the services you prefer. 
 
2.2. Purposes and legal grounds to process personal data: 
А) Data processing necessary to conclude or perform a contract for touristic and congress services. Company for International Meetings Ltd. processes your data for the following purposes:
  • Client identification when: concluding, amending or cancelling a contact for touristic and congress services; 
  • Update of your personal data or information about services you order to correct/change data/services; 
  • Service and response to client’s claims; 
  • Correction of due amount when there are grounds to do this; 
  • Bills payment, due amounts deferment, remission, postponement; 
  • Processing by people processing the data: assignment, reporting, accepting, payment; 
  • Company for International Meetings Ltd. website’s protection and safety;
 
B) Performing its legal obligations Company for International Meetings Ltd. processes your data for the following purposes: 
  • To offer contracts and draft contracts; 
  • To provide information about contracts, records, monthly bills/invoices; 
  • To provide information to competent authorities about the client and services the client has used under request/demand/check; 
  • To manage given consents; 
  • To issue invoices and detailed information about Services consumption;
  • To provide information to competent authorities for tax and insurance control; 
  • To provide information to the Commission for Consumer Protection and the Commission for Personal Data Protection regarding performance of the obligations stipulated in correspondent laws; 
  • To provide information to the Court and third persons under court procedures;
 
C) Company for International Meetings Ltd. processes the correspondent data given under client’s explicit written consent for the following purposes: 
  • To include your name, photo, video and other forms of your presence into Company for International Meetings Ltd. advertisement and media publications resulting of your participation in events organized by Company for International Meetings Ltd. or our partners; 
  • To receive and/or provide information to third persons if such information has been explicitly requested by you or if you have given your consent to receive such information. 
 
D) Company for International Meetings Ltd. processes your data for the purposes of the following legitimate interests: 
  • Make clients’ profiles for direct marketing: Company for International Meetings Ltd. uses assessment and analysis methods for some aspects of clients’ consumption, for example used services and expressed preferences, aiming to make offers for new services and/or having in view the already used services by a client, or offer a service change aiming its more effective use and client’s expenses optimization; prepare information we publish on our website in the way that is most appropriate for you; 
  • Process your bill/invoices data for other purposes compatible with their gathering original purpose;
  • Detailed analysis of clients’ preferences data (automatic encrypted processing): Company for International Meetings Ltd. makes this analysis using the data anonymously, in a form that doesn’t allow subject’s fast identification or with identification being impossible. The purpose of this analysis is services’ range development and improvement;
  • Judicial and extrajudicial collection of due amounts in cases when pending unpaid amount should be collected from Company for International Meetings Ltd.’s subscribers;
  • Audit by certified accountants employed by Company for International Meetings Ltd.;

3. Categories of third persons who can access and process your personal data: 
3.1. People processing personal data based on a contract with Company for International Meetings Ltd. They process your personal data on behalf of Company for International Meetings Ltd. or have a direct/indirect access to your personal data: 
  • Transport/express services companies that facilitate our contractual obligations performance while providing tourist and congress services; 
  • Persons employed by Company for International Meetings Ltd. To maintain equipment and software used for your personal data processing; 
  • Company for International Meetings Ltd.’s trade partners when they provide tourist and congress services; 
  • Agencies collecting unpaid due amounts, lawyers and lawyers associations/companies acting on behalf of Company for International Meetings Ltd.; 
  • Banks performing the payments you make; 
  • Security companies with holding a license for private security activity that process video records from Company for International Meetings Ltd.’s offices and/or keeping other registers while providing access into them; 
  • Persons providing paper and/or electronic archives organization, storage, indexation and destruction; 
  • Persons performing consulting in different fields. 
 
3.2. Other personal data controllers who Company for International Meetings Ltd. gives your personal data to, and who process your data on specific grounds on their own behalf: 
  • Competent authorities that under a legal act are entitled to require that Company for International Meetings Ltd. provides information including personal data (some of these authorities could be Bulgarian or other country’s court, different supervisory authorities like Commission for Consumer Protection, national security and public policy protection  authorities;
  • Insurers when concluding an insurance and Company for International Meetings Ltd. acts as an intermediary in this process in its quality of a tour operator. 
 
3.3. Joint personal data controllers who establish the goals and means for your personal data processing together with Company for International Meetings Ltd.: 
  • Credit agencies during their assessment regarding postponed payment.
 
4. How long your personal data will be preserved? 
4.1. The term of your personal data preservation depends on processing purpose they have been collected for: 
  • Personal data processed aiming to conclude and perform a contract for a Service will be preserved for contract’s term until final settlement of all relations between the parties; 
  • Personal data processed aiming to issue an accounting/financial documents for tax and insurance control (invoices, charge notices, credit notes, acceptance certificates and services contracts) will be stored at least 5 years after public claim’s payment expiry date unless the applicable legislation provides for a longer term; 
  • Personal data required for national security purposes and for serious crimes prevention, detection, and investigation, as well as for persons search and rescue operations will be kept by Company for International Meetings Ltd. for 6 months;
  • Company for International Meetings Ltd. Is entitled to preserve some your personal data for a longer term until the correspondent extinctive prescription expires aiming protection in case of possible client’s claims regarding services contract’s performance/termination, as well as in case of existing legal dispute regarding the above until this dispute’s final solution with court/arbitration verdict that has come into force; 
  • Picture (video recording) – up to 60 days counted from recordings creation.

5. What are your rights regarding personal data processed by Company for International Meetings Ltd. and what actions should you undertake to be able to exercise them: 
  • to receive access to your personal data and information of the type included into this Privacy Policy regarding cited data. You could require information from Company for International Meetings Ltd. if and for what purpose we process your personal data. You could exercise your access right visiting personally Company for International Meetings Ltd.’s office and file a written application requiring access to your personal data. The application could be filed by another person if he/she presents a Power of Attorney authorized by a Notary; 
  • require corrections in your personal data if they are inaccurate or should be complemented having in view processing purposes; 
  • require deletion of your personal data only in one of the following cases:
    • they are not necessary for the purposes they have been processed for any more;
    • you have withdrawn your consent for / objected their processing and there in no other grounds for their processing; 
    • data processing was considered illegal; 
    • this is required by national and European legislation; 
  • require limitation of your personal data processing in one of the following cases:
    • if your personal data accuracy has been contested for the term necessary to Company for International Meetings Ltd. to check data accuracy; 
    • if unlawful processing has been established but wish to limit your data processing instead of having the data deleted; 
    • you wish your data kept though Company for International Meetings Ltd. doesn’t need them for processing purposes anymore, because you intend to use these data for establishment, performance and defense of your legal claims; 
    • if you have objected your personal data processing for the time of its grounds verification;
  • to require a transfer of your personal data that concern you and that you have submitted to us, including these data receiving by Company for International Meetings Ltd. in a well-structured, widely used form readable by a machine and their transfer to another personal data operator. Your transfer right concerns personal data covering following conditions:
    • data processing is based on your explicit consent or on contractual obligation;
    • the processing is automated.
  • you can object your personal data processing in front of Company for International Meetings Ltd. at any time and for any personal reasons due to a particular situation, on grounds of the necessity to perform a task of public interest or exercising official powers; the data concerned here are the ones that have been submitted to us or the ones we have stated to be processed for our legitimate interest. If the objection is against your personal data processing for the purposes of direct marketing including profile making for the same purpose Company for International Meetings Ltd. will stop their processing for this purpose. If the objection is against your personal data processing for the rest purposes Company for International Meetings Ltd. will reply to you within reasonable time term which will not be longer than one month if the Company for International Meetings Ltd. considers your objection justified and will therefore stop processing the correspondent personal data for these purposes; 
  • if your personal data processing is based on your consent you can withdraw your consent to have your personal data processed at any time declaring your explicit wish through trade network and communication channels with Company for International Meetings Ltd.; 
  • you are entitled to submit a claim to Commission for Personal Data Protection if you consider that your rights regarding your personal data processing have been violated. To be able to exercise your rights you should file an explicit written declaration to Company for International Meetings Ltd.’s central office. For more information on how you could exercise your rights regarding your personal data, you can call Company for International Meetings Ltd.’s phone number at any time.

6. Are you entitled to refuse providing personal data to Company for International Meetings Ltd. and what will be the consequences? 
6.1. To be able to conclude a contract with you and provide the services you have ordered we need certain data necessary to conclude and perform the correspondent contract as well as to perform Company for International Meetings Ltd.’s legal obligations. If you fail to provide the following data Company for International Meetings Ltd. will be prevented from concluding a contract with you: 
  • Full names, Personal ID Number or Personal Number of a Foreigner, address; 
  • Your attorney’s full names, Personal ID Number, address and other data stated in the document you have authorized him/her with to represent you in front of Company for International Meetings Ltd.; 
  • Identification document’s number, date of issuing, expiry date and issuing authority; 
  • Data gathered for payment made to Company for International Meetings Ltd.: credit or debit card number, bank account, and other bank and payment information regarding bank payment performance; 
  • Data from your profile used to access our online platform: user name, orders and payments history. 
 
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