Privacy policy

Privacy and data protection policy

INFORMATION ABOUT THE DATA CONTROLLER

Name: Yacht Club Eternity Ltd.

UIC: BG207906434

Address: Sofia, Sofia Center, Tsar Shishman Str. 8, fl. 4

e-mail: info@eternity-club.com

Website: www.eternity-club.com

phone number: +359 883 700 772

PURPOSE, SCOPE AND ADDRESSEES OF THIS PRIVACY POLICY?

We at Yacht Club Eternity Ltd. as the data controller recognise the importance of your online privacy and believe it is important that you understand how we collect, store, share and use information about you as our customer which is personal data collected through the website "www.eternity-club.com". Therefore, through this privacy policy, we inform you about the processing carried out and about the possibilities of exercising control on your part, in accordance with the requirements of European and national legislation, namely Regulation (EU) 2016/679, the General Data Protection Regulation of the European Union and the Bulgarian Personal Data Protection Act (taken as an addendum thereof).

Information relating to your personal data as individuals or representatives of legal entities of our customers as well as visitors to our website "www.eternity-club.com" may be contained (the enumeration is not exhaustive) in: emails; paper documents; electronic documents regardless of whether they are signed with a qualified electronic signature and regardless of the medium on which they are stored. The information is collected for the purpose of concluding a contract and establishing a business relationship between us, for the provision of the services you have requested and which Yacht Club Eternity Ltd provides through its website, and during the period of validity of the same.

The Company's services are not intended for persons under the age of 16 and no personal data is intentionally collected from such persons. In the event that we become aware that personal data has been collected for persons under the age of 16, Yacht Club Eternity Ltd. will take appropriate action to obtain consent for the processing of personal data from the person who has parental/guardian responsibility for the person under the age of 16 (in their case, item 9).

TERMS AND DEFINITIONS. WHAT DATA IS PERSONAL DATA?

In accordance with the applicable provisions of Regulation 2016/679 (EU), the terms and definitions used in the Privacy Policy are as follows:

Personal data is defined as: 'Any information relating to an identified individual or an identifiable natural person ("data subject"). An identifiable individual is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, psychological, economic, cultural or social identity of that natural person."

Processing - any operation or set of operations which is performed upon personal data or a set of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Controller - a natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its determination may be laid down in Union or Member State law;

Electronic document - any content stored in electronic form, in particular textual or sound, visual or audio-visual recordings;

Supervisory Authority - the Data Protection Commission.

WHAT TYPES OF PERSONAL DATA DO WE COLLECT AND PROCESS?

When you visit our website as our customer or potential customer, Yacht Club Eternity Ltd collects and processes the following types of minimum personal data about you, which it processes as a data controller in accordance with the EU GDPR for the purpose of providing the services and products offered on our website, namely - first name, surname, last name; ID number, date and authority of issue of the identity document; address registration; bank account number and/or debit/credit card details; contact details such as mobile/landline telephone number and/or e-mail address; photographs or video images from trips; other data you have provided to us by email or telephone. Providing and agreeing to provide personal data is mandatory in order for us to respond to your enquiry and provide the products and services offered on our website accordingly (we may list them one below the other as these or leave them as they are).

In case you are a duly authorized person we process the following data: name, personal identification number, address registration, ID number, date and authority of issue indicated in the authorization, telephone number.

Basically, your data that we process will be provided to us personally by you, and when registering, requesting or placing an order made on our website you agree to provide personal information that "Yacht Club Eternity " Ltd collects, records and stores in connection with the described purposes and term of this Privacy Policy.

From time to time we may receive personal data about you from third parties, for example customers, other business partners, government and regulatory authorities and local government bodies, and when you visit our website and provide consent we may automatically collect information about your visit to our website; cookies; technical login information, browser type and version, IP address and other technologies.

"Yacht Club Eternity Ltd. does not collect or use in any way: financial information; information concerning sensitive personal data related to origin; political, religious and other beliefs; health status; criminal record; participation in trade unions and political organizations. Your data will not be processed for anything other than the provision of our products and services, by contract between the parties.

By accepting this privacy and data protection policy, you consent that your personal data may be provided to third parties in connection with the performance of the products and services provided on our website and the contract between the parties for the provision of the travel service.

RELATED SERVICES

The Company's services may also be linked to websites operated by unaffiliated companies and may include advertisements or offer content, features or applications, traffic and account analytics developed and maintained by unaffiliated companies. The Company is not responsible for the privacy practices of such unaffiliated companies.

HOW DO WE USE YOUR PERSONAL DATA?

The data that Yacht Club Eternity Ltd. collects from and about Users is used to enter into and/or perform a contract with you, to provide tourism products and services by evaluating, analyzing and improving these services according to your expectations and interests; to perform obligations arising from the conclusion of a contract for the performance of a tourism service, which may include hotel reservations, airline tickets and other necessary for the performance of the contract; to increase your level of satisfaction when using the services of the Company by providing you with relevant and interesting content; to offer you quality customer service, communicate with you and respond to your inquiries; with your prior consent, to send you (via email, SMS, phone, chat and social media) offers, and promotions related to the Company's services, services/products of affiliates and/or partner organizations operating in the real estate business. With your prior consent, we send you marketing messages tailored to your individual interests and searches via email.

By accepting this policy and providing your personal data, you give your prior and voluntary consent to Yacht Club Eterity Ltd to make videos and filming during the performance of the service provided and the contract concluded between the parties. By your prior and voluntary consent, you grant all copyrights to the videos and photographs made by "Yacht Club Eternity" Ltd. during the performance of the service provided and the contract concluded between the parties and grant the express right to "Yacht Club Eternity" Ltd. to use them for the purpose of advertising and marketing campaigns to promote the activities of "Yacht Club Eterniti" Ltd.

LEGAL BASIS ON WHICH WE COLLECT AND PROCESS YOUR PERSONAL DATA

The processing of your personal data is necessary in view of the provision of the services performed by the Company; in connection with the applicable legislation, insofar as the same imposes on "Yacht Club Eternity" Ltd. the obligation to store such data; on the basis of the legitimate interests of the Company and its contractors to carry out economic activity, insofar as the processing of personal data is carried out within the strictly necessary for the implementation of such economic activity.

In most cases, the processing of your personal data will be on one of the following grounds:

• the processing is necessary to enter into or perform a contract already concluded with you;
• the processing is provided for in a legal act or is in fulfilment of a legal obligation (for example, to disclose tax data to a government authority);
• the processing is in relation to securing our legitimate interests as a company and our interests do not conflict with your interests, fundamental rights or freedoms (e.g. our interest in the development of the Company's business and operations; in improving the efficiency of our processes and practices; in safeguarding our property, etc.)

Any User has the right to withdraw their consent to the processing of personal data at any time by sending a message to the Company's address or email address listed below. It is important to note that in order to enter into a contract with you remotely, to perform our contractual obligations in accordance with the contract and the law; to purchase and respectively provide the products and services offered on our website, " Yacht Club Eternity" Ltd. needs to collect and process personal data that identify the contracting party, its proxy (if any), contact details, recipient details and receipt of the product/service. Failure to provide the data in question is an impediment on your part to the ability to make a purchase and "Yacht Club Eternity" Ltd for the services rendered.

HOW DO WE PROCESS YOUR PERSONAL DATA?

Personal data is processed both by automatic means and manually and is protected by appropriate security measures, taking into account technical progress, implementation costs, as well as the nature, scope, context and purpose of the processing. The Company shall put in place appropriate administrative, technical, personnel and physical measures to protect personal data in its possession against loss, theft and unauthorised use, disclosure or modification. Basically, your data that we process will be provided to us personally by you. Our general approach is to retain customers' personal data only for as long as necessary to satisfy the purpose for which it was collected by us or provided by you, including for the statutory period specified.

For more information on our data retention practices, including in respect of customer data, please refer to the document "Policies and Procedures for the Retention and Destruction of Media Containing Personal Data" which is available on the Company's business premises or request information from the Company's Manager. 

CATEGORIES OF RECIPIENTS OF YOUR PERSONAL DATA

By accepting this policy, you consent to your personal data being processed for the purposes listed above and, accordingly, the categories of persons to whom your personal data may be disclosed, namely: to yourself, to colleagues in the Company, subject to the need-to-know principle, to persons if provided for by law (e.g. to supervisory authorities and employees of the Ministry of Foreign Affairs) and to persons who, under contract, process the data 
(e.g. to accounting service providers, partners of the company in connection with the performance of the travel service under a contract between you and Yacht Club Eternity Ltd).

PRIVACY OF YOUR PERSONAL DATA

We follow reasonable physical, technical and administrative security standards designed to protect your personal data from loss, misuse, alteration, destruction or damage, as required by European and national law.

Your personal data may be processed and stored in any country where there are members or partners of Yacht Club Eternity Ltd . We do not provide your personal data to persons outside the European Economic Area or to international organisations that are not partners of Yacht Club Eternity Ltd.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

The Company will take steps in accordance with applicable European Union law and the Bulgarian Personal Data Protection Act to keep your personal data accurate, complete and up to date.

In respect of your data that we process as a controller, you have the right to request:

• The removal of inaccurate personal data (including the completion of incomplete personal data, which may be done by you signing a declaration);
• The right to rectification, updating of inaccurate personal data or erasure/deletion of personal data;
• The erasure/deletion of personal data applicable only in the following cases:
• The personal data is no longer necessary for the purposes for which it is processed;
• In the event that you withdraw your consent to processing (only applicable where the lawful basis for processing is consent) and there is no other lawful basis for processing;
• The personal data has been unlawfully processed;
• Erasure is necessary to comply with a legal obligation under EU or Member State law to which the controller is subject.
• You have objected to the processing and there are no legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
• Right to restrict processing to storage only where:
• You contest the accuracy of the personal data for a period that would allow us to verify the accuracy of that data;
• The processing is unlawful, but you do not want the personal data to be erased, but request instead that its use be restricted;
• We no longer need your personal data for the purposes of the processing but you require it for the establishment, exercise or defence of legal claims;
• You have objected to the processing where the lawful basis is "processing necessary for the purposes of the legitimate interests of the controller or of a third party", pending verification that our legitimate interests as controller override your interests as a data subject.
• The right to request a copy of your personal data stored with the company, information about the purposes of processing and the recipients of your personal data. Before providing this information, we will require proof of your identity.
• Withdrawal of consent to the processing of personal data - if the lawful basis for processing your personal data is consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of the processing that has been carried out up to the time of withdrawal (clause 4.1).
• You have the right to lodge a complaint with the Data Protection Supervisor (https://www.cpdp.bg/) or seek redress before the competent court.

You are advised that you may exercise the above rights by submitting a written request to do so (Form 1) to the Manager of the Company. The request should be considered and within 1 /one/ month of receipt, the Company will provide you with information on the action taken in relation to the request. If the Company does not act on your request, you will be informed of the reasons for this and of the possibility of lodging a complaint with a supervisory authority and seeking redress in court within the aforementioned period. In all of the above cases, we may contact you and request additional information in order to comply with your request. 

STORAGE PERIODS FOR PERSONAL DATA

Our general approach is to retain customers' personal data only for as long as is necessary to satisfy the purpose for which it was collected by us or provided by you, including for the statutory period specified, but no longer than 5 (five) years. The storage is also made in connection with the fulfilment of the provisions of the Accountancy Act for the keeping of regular accounts and the provision of information to the National Registry Agency in connection with compliance with the legislation under the Tax and Social Security Procedural Code 

At the end of the retention period, your personal data will either be deleted, anonymised or aggregated.

UPDATING THE CURRENT PRIVACY POLICY

"Yacht Club Eternity " Ltd. has the right to amend or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and clarifications, directions, decisions, opinions and orders relating to such applicable law. Any changes to this Privacy Policy will be announced in advance by posting on the Company's website.

CONTACT US

If you have any questions or concerns about the processing of your personal data, or if you require any further information or wish to exercise any of your rights, please contact the Company Manager by any of the following means:

• By e-mail: info@eternity-club.com;
• By post or courier to: Sofia City, Sofia Center, Tsar Shishman Str. 8, 4.fl.

By accepting this policy (whether to write as them click on the button I Agree/Accept) you give your consent to " Yacht Club Eternity " Ltd. to collect, process and store your personal data in accordance with the conditions described above for the purpose of concluding a remote contract between you " Yacht Club Eternity " Ltd. for the provision of products and services offered on the website www.eternity-club.com.