PRIVACY POLICY of "INNOCITY" LTD.

This privacy policy is adopted in accordance with the requirements of REGULATION (EU) 2016/679 of the European Parliament and Council and aims to inform you of your rights, regarding the processing of your personal data. Please read this document carefully, as it is designed to clarify the basic rules that Innocity Ltd. (hereinafter referred to as the ‘Company’) follows while collecting and processing your personal data.

  1. CONTROLLER OF PERSONAL DATA:

    Name and legal form: INNOCITY Ltd.,

    UIC: 204808426

    Seat and address of administration: Montana, 33 Nikola Vaptsarov Str., fl. 1

    Represented by: Ivaylo Todorov Iliev

    Person collecting and processing personal data:

    Cloud Faces Software Services GmbH

    Phone: 0886 109 183

    E-mail: support@cloudfaces.com

    Innocity Ltd. is a company, registered in the Republic of Bulgaria, which, with the cooperation of the Municipality of Varna, is implementing the Varna City Card Program.

    Varna City Card is a program, jointly implemented by Innocity Ltd., the Municipality of Varna, and their partners on the territory of the city of Varna, in which they provide for a fee, charged to the citizens and the guests of the Municipality of Varna, the opportunity to receive at preferential terms tourist, cultural and/or sports services, offered by the partners. Citizens and guests, who have bought Varna City Card receive the right to visit certain tourist sites in Varna /landmarks, museums, cultural monuments /, and to get certain discounts at chosen units for relax and entertainment /points of interest/. The services are used by purchasing and validating Varna City Card on technical or identification medium (cards, QR code, mobile application).

    In order to purchase and use Varna City Card, you must provide your personal data.

  2. PERSONAL DATA

    What does "Personal Data of Individuals (natural persons)" mean – it means all data that can be used to identify one individual.

    The personal data you provide to the Company by the registration in the Varna City Card mobile application

    • Name
    • Age *
    • Nationality
    • Address
    • Telephone
    • E-mail address
    • IMEI code of your mobile device (International ID for Mobile Devices)
    • Photos **
    • Facebook profile data ***
    • Bank account number ****

    * By registration in the mobile application you should select your age in order to be able to purchase the card, as well as to receive information on points of interest, that might intrigue a person of your age (or age group);

    ** By registration in the mobile application, you could post/upload your profile photo. Please take into account, that the photos are not among the personal data we need to sign a contract and they are uploaded entirely at your request.

    *** By registration in the mobile app via the social network Facebook, you provide all your data from your profile account in the social network, such as name, date of birth, email, and any other information, photos, interests, events you have listed social network. Please keep in mind that your Facebook profile data is not among the personal data we need to sign a contract, and these are provided entirely at your request.

    **** You should keep in mind that when you buy Varna City Card via a POS (point of service) payment terminal you provide your bank account details. Your bank account data is not one of the personal data we need to sign a contract and it is provided entirely at your request.

    FOR WHAT PURPOSE DO YOU PROVIDE YOUR PERSONAL DATA:

    1. Conclusion and execution of a contract

      You provide the abovementioned personal data, because we need it to conclude a contract for the sale - purchase of Varna City Card and to identify you as a party to the set contract. Besides for the purposes of concluding the contract, your personal data is also collected for the performance of this contract, in which both parties – You, as a Buyer, and the Company, as a Seller, have the obligation to fulfill the terms within the specified deadlines. By registering in the mobile application you create a profile account, which account does not create any obligation for you to purchase Varna City Card.

      Legal basis for processing - Art. 6, item 1, letter. "b" of Regulation 2016/679 of the European Parliament and of the Council; CPA; T3; CPC; LMML;

    2. Protection of the rights of the Company in case of non- performance of the contract

      Besides for the conclusion and performance of a contract, your personal data is also collected in caseof non-performance of this contract. This way, for the entire term of the contract, both parties to it - You, as a Buyer and the Company, as a Seller, have the obligation to fulfill the conditions, provided within the contract in the specified deadlines, and any action that deviates from the arrangement entitles each one of the parties to defend its rights in the appropriate manner, including by using the necessary personal data.

      Legal basis for processing - Art. 6, item 1, letter. "f" of Regulation 2016/679 of the European Parliament and of the Council; CPA; T3; CPC; LMML;

    3. Accounting and tax purposes

      Data on the contracts, concluded between us, are stored and processed in relation to the obligations of all persons to perform and maintain tax accounting and to pay taxes. In this case, your personal data can be processed entirely for tax purposes.

      Legal basis for processing - Art. 6, item 1, letter "c" of Regulation 2016/679 of the European Parliament and of the Council; Zcc; CITA; ЗЗДФЛ; T3;

    4. Statistical purpose

      Following the completion of the agreement between us, the Company keeps your personal data for statistical purposes. In this case, pseudonymization is performed - your personal data is processed in such a way that it can not be linked to you and you can not be identified.

      Legal basis for processing - Art. 6, item 1, letter. "f" of Regulation 2016/679 of the European Parliament and of the Council; T3;

    5. Keeping a mobile application account

      By signing up for the mobile application (new registration or registration through Facebook social profile), you create a profile for your mobile which account does not create any obligation for you to purchase Varna City Card. In this case, Innocity Ltd. keeps your personal data in order to be able to maintain a profile in the mobile application.

    HOW IS YOUR PERSONAL DATA COLLECTED

    Your personal data will only be provided by you, at your request and upon confirmation by you, that you wish to enter into a contract for the purchase of Varna City Card.

    You choose how you to provide us with your personal data - by signing up for the Varna City Card mobile application, by signing up with a Facebook profile, by email or in another suitable way.

    By registering a profile in Varna City Card mobile application and purchasing an information carring medium, you provide your personal information. To complete your registration and to be able to use the mobile application, you must agree to the use of your personal information as outlined above.

    HOW WE STORE YOUR PERSONAL DATA

    Your personal data is stored on electronic carrier. Your personal data is stored on an electronic medium - a computer. The computer is equipped with licensed software and has the necessary protection programs, including protection from viruses. The computer is restricted to external users by a password.

    HOW LONG IS THE PERSONAL DATA STORED

    Your personal data is stored for different terms, depending on the purpose for which it is collected.

    1. Conclusion, execution and protection of the rights of the Company in case of non-fulfillment of the contract of the contract - term of up to 10 years from the date on which the full and final performance of the contract occurs by the parties or the termination of the contract on another ground.
    2. In case of a breach of contract and one of the parties has taken action to defend its rights by judicial /administrative or other manner - up to 5 years from the date of the final judicial, administrative or other act.
    3. Accounting and tax purposes - up to 10 years from the date of the last payment. If the revenue administration and /or other public authorities initiate revisions and /or inspections, the period for the storage of personal data may be extended by the duration of the relevant state administration activities.
    4. Statistical purposes - up to 10 years from the date of purchase of the card.
    5. Mobile account maintenance - up to 10 years from the date your account / mobile application was deleted.

    In case of a breach of contract and one of the parties has taken action to protect its rights in judicial /administrative or other manner to which “Innocity Ltd. is a part of - up to 5 years from the date on which the final judicial, administrative or other act was issued.

    HOW THE PERSONAL DATA ARE DESTROYED

    To avoid any unwanted negative consequences in relation to the processing of your personal data, by the expiry of the term for which the personal data are stored, the latter shall be destroyed/pseudonymized in such a way that you can not be identified.

    HOW WE STORE YOUR PERSONAL DATA

    Your personal data is stored on electronic carrier. Your personal data is stored on an electronic medium - a computer. The computer is equipped with licensed software and has the necessary protection programs, including protection from viruses. The computer is restricted to external users by a password.

    DO WE PROVIDE DATA TO OTHER PERSONS?

    Your personal data may be provided to others, depending on the purposes for which the data is stored, namely:

    1. Registration and maintenance of a profile in the mobile application concluding, implementation and protection of the Company's rights in case of non-fulfillment of the contract for the sale- trade of Varna City Card on technical and information medium - for registration and maintenance of a profile in the mobile application, for the conclusion of a contract for the sale-purchase of Varna City Card on technical and information medium (card, QR code, mobile application), for protection of the rights of one of the parties in the relevant judicial, administrative or other matter - to Attorney-at-law, notary, accountant / accountancy office, Registry Agency, court, prosecutor's office, State Agency for National Security, established courier company, Bulgarian Post Jsc, people responsible for technical and software maintenance of the equipment (IT specialists). In case you want to find the exact name of the people to whom your personal data has been provided, please contact us at the email, address and phone provided in section I above.
    2. Accounting and tax purposes - of accountants and accounting offices, of the competent state and municipal authorities upon request of them, eg. National Revenue Agency, Local Taxes and Fees Department at Varna Municipality, State Agency for National Security and others.
    3. Statistical purposes - these data are not provided to other people, except for shareholders representing them, employees of the Company and the competent state and judicial authorities, if it’s necessary and requested by them.

    ATTENTION:Your personal data may be provided to the Commission for the protection of personal data when exercising its powers of control over compliance with the provisions of Regulation (EC) 2016/679 of the European Parliament and of the Council.

  3. WHAT ARE YOUR RIGHTS with reference to your personal data processed by us?

    1. Right to access, correct, delete, limit the processing of your data

      You have the right to receive information about whether we process your personal data, exactly which personal data we process, which person process it, whether it is provided to others, how long it is processed, what your rights are in relation to your personal data, whether you have the right to appeal. You may receive a copy of your personal data, which we process. In addition, you have the right to ask us to update/correct your personal information if the information we have is incorrect (for example, if we store personal data from expired identify document). You have the right to request from us not to take any action on your data but only to store it (the so-called restriction of processing) and to request the erasure of your personal data when it is no longer necessary for the purposes, for which they are being processed, and after the expiry of the period for which they are stored.

      ATTENTION:You submit your personal data by your choice, based on your own decision, as Innocity Ltd. does not perform any profiling or automated processing of your personal data.

    2. Right to data transfer

      You have the right to receive your personal data that you have provided us with and which we process in a structured and widely used format. In addition, you are entitled to transfer your personal data under the previous sentence to other people and/or administrators, either personally or by transferring our data to another administrator you provide, if it’s technically possible.

    3. Right of objection

      The provisions of the Regulation provide for your right of objection in cases where your personal data are processed for the performance of a public interest task or where the processing is necessary for the purposes or legitimate interests of the Company or a third party, when the legal bases for processing your data are based on Art. 6 (1) (e) and (f) of the Regulation. In such cases, you have the right to object and request that we discontinue the processing of your personal data. If you choose to file such an objection, we will review your request and respond to you in the appropriate order and within one month, unless it is technically necessary to take longer time.

    4. Right to appeal

      You can file a complaint with the Personal Data Protection Commission to protect your rights and legitimate interests in dealing with them.

      ATTENTION:If you need any further information regarding the collection, processing, storage, destruction or any other information related to your personal data, please contact us at the above address, phone number and e-mail address. Our team will answer all of your questions.