Privacy Policy on the processing of personal data
This is an unofficial translation provided for convenience only. The Bulgarian version is the legally binding original; in the event of any discrepancy, the Bulgarian text prevails.
This privacy policy is intended to inform you how moidom.eu treats your personal data as a controller. Our team’s core mission is to provide you with comprehensive and objective information about the options for letting property on a short-term or long-term basis.
We consider guaranteeing the right to protection of personal data to be a fundamental commitment, which is why we will use and invest all necessary means and efforts to process your data in full compliance with Regulation (EU) 2016/679 (the “EU General Data Protection Regulation” or “GDPR”) and any other applicable national legislation. Since one of the core principles of this legal framework is transparency, we have prepared this document to inform you of the way in which we collect, use, transfer and protect your personal data when you interact with us in relation to products and services, including through our website.
We reserve the right to update and amend this Privacy Policy periodically, in order to reflect any changes in the way we process your personal data or changes in your legal requirements. In the event of such changes, we publish the amended version of the Privacy Policy on our website and therefore kindly ask you to check its content from time to time.
Terms and definitions used
“Personal data” – any information relating to you through which you can be identified directly or indirectly, in particular by an identifier such as names, personal identification number, location data, telephone, e-mail address, or by one or more features specific to your identity.
“Processing of personal data” – any action or set of actions which may be performed in relation to your personal data by automated or other means, such as collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure or transmission, dissemination, updating or combination, blocking, erasure or destruction of the data.
Principles in the processing of personal data
Principle of transparency and information – moidom.eu collects, processes and stores your personal data under clear and transparent conditions. It is of paramount importance to us that you are informed why and how we carry out these processes.
Principle of consent – except in cases provided for by law, your voluntary, explicit, informed and unambiguous consent is a precondition for moidom.eu to collect, process and store your personal data.
Principle of limited collection – moidom.eu collects personal data to a minimal extent, only for the purpose and for the period for which they are necessary.
Principle of limited use, disclosure and storage – moidom.eu does not use your personal data for purposes other than those for which they were collected, except with your consent or in the cases expressly provided for by law.
Principle of security and safeguarding – your personal data are protected by technical and organisational security measures taken by moidom.eu in accordance with the sensitivity of the information.
Types of personal data that moidom.eu collects, processes and stores
Registration on the site is not required in order to use the services provided by moidom.eu.
Data collected for all visitors to our website:
- IP address
- A highly unique user identifier
- A highly unique browser identifier
- History of the pages visited, including secondary processing for the purpose of establishing your preferences for certain types of content
- History of the searches you have made on the site
- Certain types of behaviour – e.g. a list of the adverts viewed by category and your interaction with them – whether the advert was in the visible part of your browser; clicks made; presses of the buttons to hide the advert, and others
Data collected when you send an enquiry to our e-mail address:
- Names
- Contact telephone number
- Home address (necessary for the provision of our services)
- Payment details
Data collected from reading cookies: When users use our services, read news, watch video and so on, cookies are among the data that help us understand how our services work best and to make them even better for you. They are small text files that are sent from the web server to the browser used and are stored on your device so that the site can recognise it. There are two types of cookies – persistent and temporary or “session” cookies. Persistent cookies are stored as a file on your computer or mobile device for a longer period of time. Session cookies are stored temporarily on your computer when you visit our site, but are deleted the moment you close the page. Most cookies do not contain sensitive information about you or personal data by which we can identify you directly. The purposes for which we use cookies are most fundamentally to track your behaviour in the following respects:
- Tracking the sections of the site you visit
- How much time you spend on the site
- How long you watch a given video
- The adverts you have seen and/or interacted with
- When you visit our site, and others
To add and manage comments we use the solution provided by WordPress and Akismet, giving it the ability to collect personal data provided by you, according to the way you access the solution:
- Names and e-mail address
- The comments themselves are public, which is why we kindly ask you not to add personal data or any information you would not want to see publicly shared in them
Under none of the options listed do we have access to your information, since the technical solution applied by Akismet does not permit this. In order to exercise your rights under the GDPR in relation to the comments you leave, you will need to contact Akismet.
Purposes of the processing of personal data
Moidom.eu collects, processes and stores personal data for the following purposes:
- on the basis of legitimate interest, for the purposes of providing our services in supplying information about the options for letting property on a short-term or long-term basis
- for the purposes of examining a report and/or enquiry submitted by you – for checking against the moidom.eu database
- protection of our legitimate interests – there may be cases in which we use or transmit information in order to protect our rights and our commercial activity. These may include: measures to protect the website and the users of the moidom.eu platform against cyberattacks; measures to prevent and detect attempted fraud, including the transmission of information to the competent public authorities; measures to manage various other risks
- for the purposes of direct marketing to offer services provided by moidom.eu (sending offers/commercial communications and others by post, to an electronic address, by telephone or by another direct means), statistical research and analysis, only where explicit consent has been given for this purpose
The main reason for these types of processing is our legitimate interests relating to the protection of our commercial activity, with the proviso that we guarantee that all measures we take ensure a balance between our interests and your fundamental rights and freedoms.
Categories of persons to whom moidom.eu discloses personal data
Moidom.eu does not grant the right to use, does not sell, does not disclose and does not share information about you (personal data within the meaning of the GDPR) with other persons or with unrelated companies, except where this is necessary in order to offer you high-quality, fast and comprehensive service and for our products and services to meet your expectations, and where you have given your permission, or in one of the following situations:
The information is provided to trusted partners who work on assignment from moidom.eu on the basis of contractual relations and under confidentiality agreements. These companies may use such information so that moidom.eu is able to deliver advertising to its users.
Nevertheless, these companies do not have the right to share this information independently. These companies are, without the list being exhaustive:
- Google with its respective products: Google Analytics, Google Tag Manager, DoubleClick for Publishers, AdX, AdSense, Google Case, Google IMA, Google Plus
- Facebook with its respective products: Facebook Tracking Pixel, Facebook Tools – Plug-in “like” button, Sign in with Facebook profile and others
Competent authorities which, by virtue of a legal act, have the power to require the Controller to provide information, including personal data, such as a Bulgarian court or a court of another state, various supervisory/regulatory bodies – the Consumer Protection Commission, the Communications Regulation Commission, bodies with powers relating to the protection of national security and public order, and others.
Retention period for personal data
We intend to retain your personal data only for as long as is necessary in accordance with our Data Retention Policy, no longer than is necessary to achieve the purposes listed in these rules and/or as required by applicable law, including compliance with the applicable statutory provisions on minimum retention periods and/or where necessary for the exercise of our legitimate rights (and those of third parties).
Where moidom.eu processes your data in connection with providing you with information about the options for EU funding of projects, including through electronic communication following an enquiry from you, the data provided are stored for a period of no more than 1 year.
Where we process your personal data on the basis of consent, that personal data will be processed only for the period for which your consent has been given, unless you have withdrawn or restricted your consent before the expiry of that period. In such cases we will cease processing the personal data concerned for the relevant purposes, subject to the statutory obligations regarding the processing of personal data and/or obligations arising from the need to process that personal data in order to exercise our legitimate rights (including those of third parties).
In the event of a legal dispute, proceedings and/or a request from a competent state authority, moidom.eu may retain your data for longer than the periods indicated, until the dispute or proceedings before all instances have been finally concluded.
Protection of personal data
We store your data on our servers and on servers hosted by third parties. We use appropriate technical and organisational measures intended to protect your personal data and prevent unauthorised access. We have contracts with our hosting service providers that include obligations relating to safeguarding the organisational and technical security of personal data.
The transmission of data over the internet is not fully secure. Although we will do what depends on us to protect your data, we cannot guarantee the security of your data transmitted via the site; any transmission of data is at your own risk. Once we have received your data, we will apply strict procedures and security features with a view to preventing unauthorised access.
Clients’ rights regarding their personal data
You have the following rights in connection with the collection, processing and storage of your personal data by moidom.eu:
- Right to information – the right at any time to request from moidom.eu information about the personal data stored about you by moidom.eu, as well as about their origin, the recipients or categories of recipients to whom they are transferred, and the purpose of the storage.
- Right of access – the right to obtain confirmation as to whether moidom.eu processes your personal data, the right of access to them, and information about their processing.
- Right to rectification – the right to request that moidom.eu promptly correct and/or complete inaccurate personal data about you stored by moidom.eu.
- Right to erasure (the right “to be forgotten”) – the right to request that moidom.eu erase (delete) or block your personal data whose processing does not meet the requirements of the Personal Data Protection Act and the Regulation, and to notify the third parties to whom those data have been disclosed of any such erasure or blocking, save in cases where this is impossible and/or where there is a substantial ground and/or statutory obligation for their processing.
- Right to restriction of processing – the right to require moidom.eu to restrict the processing of your personal data where you contest the accuracy of the data (for the period of verification), where the processing is without legal basis but you prefer restricted processing instead of erasure, or where you have lodged an objection and are awaiting verification of whether moidom.eu’s grounds are lawful.
- Right to data portability – the right to receive the personal data which you have provided to moidom.eu and which relate to you, in a structured, commonly used, machine-readable format, and to use those data with another controller of your choosing.
- Right to object – at any time you have the right to object to the processing of your personal data by moidom.eu where there is a legal basis for this, including for the purposes of direct marketing. Where the objection is well founded, moidom.eu’s right to process the personal data ceases.
- Right not to be subject to a decision based solely on automated processing, including profiling – the right to request human intervention on the part of moidom.eu in the processing of your data, the right to contest moidom.eu’s decision and the right to express your point of view.
- Right to withdraw consent – the right to withdraw at any time the consent you have given for the collection, processing and storage by moidom.eu of your personal data (such as consent for marketing purposes). The withdrawal of consent will not affect the lawfulness of processing carried out before it.
- Right to lodge a complaint with a supervisory authority – if you believe that we are infringing the applicable rules on the processing of your personal data, we ask you to contact us to clarify the matter. Of course, you have the right to lodge a complaint with a supervisory authority, which in the Republic of Bulgaria is the Commission for Personal Data Protection, at: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., telephone 02/91-53-518; e-mail: kzld@cpdp.bg
Procedure for exercising rights regarding personal data
In order to exercise the rights described above, you should submit a request/application to moidom.eu containing at least the following information:
- Your name, address, telephone
- a description of the request
- the preferred form for providing the information
- signature, date of submission of the request/application and correspondence address
Submitting the request/application is free of charge. You can submit it electronically to the following e-mail address: contact@moidom.eu
The period for examining the request/application and issuing a decision on it is up to 60 days from receipt of the request/application, without undue delay.
Moidom.eu will prepare a written response and communicate it to you personally – against signature or by sending it to you via a courier company with acknowledgement of receipt, taking into account your preferred form for providing the information.
Where the data do not exist or their provision is prohibited by law, you will be refused access to them.
In the event that moidom.eu does not respond to your request for access to personal data within the prescribed periods, or you are not satisfied with the response received and/or you consider that your rights relating to the protection of personal data have been infringed, you have the opportunity to exercise your right of protection through judicial or administrative channels.
Contact details
If you have questions or uncertainties about the processing of your personal data, or wish to exercise any of your rights, you can contact us by e-mail at: contact@moidom.eu or write to us at: Sofia, 2 Aleko Konstantinov St.
Please do not disclose any sensitive personal data when contacting us (e.g. information relating to racial or ethnic origin, political opinions, religion or other beliefs, health or trade union membership, information about criminal convictions, and others).