NOTIFICATION OF CONFIDENTIALITY
This Notification of Confidentiality in reference to personal data (hereinafter referred to as „the Notification“) aims to inform our customers about how ALEKSIA AUTO LTD. („we“, „us“, „our“) collect and process personal data in the process of carrying out the activity of rent-a-car.

GENERAL PROVISIONS
Please have in mind that pursuant to the legislation, including Regulation ЕС 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, effective as of 25 May 2018 („Regulation“), „personal data“ (hereinafter referred to also as „data“ or „your data“) shall mean any information or a set of information through which, directly or indirectly, your identity may be ascertained, in particular using an identifier, such as name, identification number, e-mail account, telephone number, data about location, etc. Or through one or more signs specific for your physical, economical, cultural or social identity.
The controller of your data related to booking and/or renting a car Green rent-a car shall be ALEKSIA AUTO LTD., UIC: 202516238, registered and management address: the town of Pomorie, 17-19 Evropa Str. The contact details and methods of contact with us are specified at the end of the Notification.

WHAT KIND OF DATA DO WE COLLECT AND FOR WHAT PURPOSES?
When you address us, irrespective of whether at our customer service center or through our internet site www.greenrentacar.bg, we can receive directly from you or ask that you provide us with certain information about yourself. In most cases ,we require your personal data for the purposes of concluding a contact, to fulfil a statutory obligation or to protect our legal interest. Without those data, we could not make a booking, or conclude with you a car rental agreement. Of course, for part of our services, you will be the one to provide this information, choosing and agreeing to send us information about yourself. In case you share with us data of other persons (such as data of an additional driver or of persons accompanying you in reference to the concluding of additional insurances), you will be responsible for the collection of those data in compliance with the statutory requirement and the obligation to notify the persons whose data you provide us with and to acquaint them with the Notification.
Depending on the service you use, we may collect and process the following information about you:
 
 Data categories Types of data Purpose of use
Personal data for identification Data according to ID card or passport – names, PIN or date of birth To identify you in the course of booking or concluding of a rental agreement, and in fulfilment of statutory requirements
Data about identity document ID card or passport number, date and place of issue, end date In reference to concluding or execution of a rental agreement
Data of driving licence Document number, date and place of issue and end date, date of acquired competence In reference to concluding and execution of a rental agreement and in fulfilment of statutory requirements
Address Permanent address and residence address in the territory of the country if you are a foreigner An option for contact with you in reference to the execution of a rental agreement
For protection of a legal interest
Data with contact details Telephone number and e-mail address Option to contact you in reference to concluding and execution of a contract, for example where we send a confirmation of your booking or contact you in case of necessity
The provided contact data will not be used by us for marketing or other purposes without your explicit consent.
Data about user account User name, e-mail account, password For the purposes of creating an account and personal setting, and management of the used services
Financial data IBAN/account number, data about credit/debit card as well as other bank details
 
Issuing of financial and accounting documents related to booking and/or  concluded contract such as invoices and bills, and in reference to payment of provided services
 
Data about your health status Information about your health status, including information about diseases or disabilities Concluding of additional insurances requiring preliminary information provided with your consent.
Settlement of insurance claims or other claims related to damages during or in reference to the  execution of a rental agreement.
Traffic data Information about your device, date and duration of the access, information about the browser and the information system you use, IP address To protect the interests of the Company to ensure the security of our internal communications and systems, protection from viruses and other malware.
To obtain information about the traffic of our internet site.
Data about positioning GPS tracking of the rented cars For protection of the interests to ensure the security of our property and execute a concluded contract.
Video record Your images on records from video surveillance at certain section of our customer service centers or parking lots. For protection of the interests for ensuring the safety of the property, the information and premises, and to guarantee the security of employees and visitors.
Audio record Record of your voice when calling to the national contact telephone In reference to providing our services and customer service
 
ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR DATA?
To be able to process your data, the Company shall refer to various legal grounds, including:
  • For concluding and execution of a rental agreement, or the services related to it that we offer;
  • For execution of our statutory obligations,  for example, obligations envisaged in the tax legislation or the necessity that we provide information to administrative or judicial authorities;
  • Our legitimate interest, including to ensure protection of premises, property, networks and information, employees and visitors; to establish, exercise our rights under, or to protect ourselves from legal claims;
  • Your explicit consent (only where it is required or permitted by law), for example for using some “biscuits” or for sending promotional offers, questionnaires for assessment of the services provided by us, etc. If the Company refers to your consent as legal grounds to process your data, you can withdraw your consent at any time.
WHOM DO WE SHARE YOUR DATA WITH?
In the course of realization of our activity, we have to share your data with some of the following categories of persons:
  • Regulatory, governmental and judicial authorities
We can disclose and provide your data to the competent governmental authorities under the statutory procedure and in the cases where there is the relevant obligation to provide them. We can disclose and provide your data to the competent governmental authorities also in the cases where we have certain administrative or property responsibility as the owner of the rented car – for example, in case of an offence of the traffic regulations committed by you and ascertained by technical means.
  • Service suppliers
The category of your data is determined according to the necessity and nature of the ordered services – for example, banks and other suppliers of paid services with whom, we arrange payments or guarantees to pay, accountants, auditors and lawyers; suppliers of services such as construction and maintenance of ERP or IT systems, hosting service; to private enforcement agents in reference to the realization of the legitimate interests of the Company in case of necessity of enforcement collection of the amounts due by you.
  • Business partners
The Company may provide your names, contact telephone and e-mail account to third parties, our suppliers or customers, who help us to provide our services.
The Company will provide your data to other parties if this becomes necessary in order to achieve the objectives of their processing after you are notified and receiving your consent, as applicable.
In all cases, we conclude written contracts with our service suppliers and business partners and require that they guarantee the protection of your personal data.
Please, have in mind that our internet site may contain links to other pages and social networks that we do not control and we have no responsibility of the manner of processing of personal data. It is recommended that you get acquainted with the policies and the information about confidentiality of each internet site you visit. This Notification refers only to the data we collect through our internet site or in another manner.

TRANSMISSIONOF DATA OUTSIDE BULGARIA
We don’t intend to provide your data to persons or organization outside the territory of the European Union. If this has to be done in exception cases, we will notify you in advance and take the necessary measures of protection.

HOW LONG DO WE PROCESS YOUR DATA?
We process your data for as long as is necessary to achieve the objectives for which they were collected or until the end of the statutory term.
It is our legitimate interest to keep certain personal information of yours after the end of the agreement. According to the approved internal policy, the terms for keeping of some of the data categories are:
  • 5 years after the execution of the agreement – until the end of the statutory preclusive or limitation terms for bringing claims;
  • 10 years for accounting data;
  • Up to 3 months for audio and video records;
  • Up to 3 months for traffic data and data about geolocation.
Irrespective of the above terms, we will not erase any data if they are necessary for the purposes of pending administrative or judicial proceedings, or in the procedure of settling insurance claims. 

HOW DO WE PROTECT YOUR DATA?
To protect your data, we have introduced and will continue to undertake the necessary measures in compliance with the existing provisions and laws for personal data protection and the data security and including, we will require from our service providers to apply the necessary measures for protection of personal data and the security of your data. Depending on the up-to-dateness, the expenses for applying and the nature of the data that should be protected, we have implemented technical and organizational measures so that we avoid and prevent risks such as destruction, loss, change, unauthorized access, unauthorized or ill-intentioned use of your data.

AUTOMATED ALGORITHMS AND PROFILING
We do not use software for automated processing of your personal data and decision-making, including for your profiling.

WHAT ARE YOUR RIGHTS IN REFERENCE TO THE PERSONAL DATA PROCESSED BY US?
Pursuant to the provisions of the General Data Protection Regulation (EU 2016/679), you have certain rights in reference to your personal data, and you should have in mind that some of those rights may arise and be exercised only with certain grounds for processing your personal data and part of your rights must suffer some limitations or exclusions.
In compliance with the applicable legislation and with the prerequisites stipulated in it, you have the right:
  • to access to your data;
You have the right to request information as to whether we process your personal data, what categories, for what purposes, whom we will provide with your data etc. Based on your written request, we will provide you will a free copy of your personal data we process. We preserve the right to ask for payment of a charge for providing additional copies in case of excessively repeated submitted such requests. 
  • To require correction of inaccuracies in your personal data;
We commit ourselves to correct or supplement inaccurate data upon receiving the relevant request from you. We would like to remind you that it is your responsibility to ensure, as much as possible for you, the accuracy, comprehensiveness and up-to-dateness of the data you provide us with.
  • To require limitation of the processing of your personal data;
You have the right to require that we limit the processing in any of the listed cases: if you challenge the accuracy of your data; if the processing is illegal but you do not wish that the data are erased, instead you require the limitation of their processing; if we do not need the data any longer but you require them in order to ascertain, exercise or protect legal claims; or if you have objected against the processing of data based on legitimate interest.
  • To require the erasing of your personal data;
You have the right to request the erasure of your data: where they are no longer necessary for the purposes for which they were collected, where you have withdrawn your consent for their processing and there is no other legal ground for the processing or when you object against processing based on a legitimate interest and this interest has no precedence over your rights. In spite of your request for erasure, we have the right to continue to process your personal data in order to observe our statutory obligations or where the processing is necessary to establish, exercise or protect legal claims.
  • To object against each processing of your personal data which is not based on the legitimate interests of the Company.
In this case, we will discontinue the processing, except if there are convincing legitimate grounds for processing that have precedence over your interests, rights and freedoms.
  • Of portability of your personal data;
You  may exercise the right of portability only in the cases where the data are processed in automated manner and where we process your data on the basis of your consent or on the basis of contract to which you are a party. You should have in mind that the exercising the right of portability does not result in erasure of your data. With the specified prerequisites, you have the right to receive your data in a structured, widely used and machine-readable format or to request your data to be transferred to another controller if this is technically feasible.
  • In the cases in which we process your data on the basis of a consent given by you, you have the right to withdraw your consent at any time;
If you withdraw your consent, this will not affect the regularity of the data processing before the withdrawal.
  • To submit a complaint to the competent supervisory authority if your rights have been violated or to approach the court if you have suffered from unlawful processing of your personal data.
If you think that we do not process your personal data in compliance with the applicable legal frame, please, contact us to clarify the matter. Nevertheless, you have the right to submit a complaint to the Commission for Data Protection or to seek protection of your rights under judicial procedure.

DO YOU HAVE QUESTIONS OR YOU WANT TO SUBMIT A COMPLAINT?
If you have any questions in reference to the processing of your data or  wish to exercise your relevant rights, you may address the Personal Data Protection Officer:  
  • at telephone: 0885/ 889 100
  • on the spot at the administrative office: the city of Burgas, 19 Industrialna Str.,
  • Monday to Friday 9:00 - 18:00ч or
  • to e-mail: office@greenrentacar.bg
Your request or complaint may be sent in electronic or written form and you have the option to use the Template for Request by Data Subject that you may receive at any of our customer service center or download from our internet site (www.greenrentacar.bg). 
In case of submission of a request/complaint by e-mail, it is necessary that it comes from the e-mail account used for your registration in the information system at www.greenrentacar.bg and provided personally by you in the course of booking or concluding of a car rental agreement. 
Where the request is submitted in writing, it is necessary that you submit it personally or by authorizing another person explicitly with a notarized power of attorney.
If you think that the Company processes your data illegally, you have the right to submit a complaint to the Commission for Protection of Personal Data at address:
The city of Sofia 1592
2 Tsvetan Lazarov Blvd.
e-mail:  kzld@cpdp.bg
internet site: www.cpdp.bg
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