Personal data protection policy of Unseen Pro Ltd
in the implementation of its activity - electronic sales (online) of tickets for cultural events through the Entase web platform
This policy aims to inform users of the Entase web platform for the collection of their personal data via this website or directly received by phone or email.
Certain measures have been implemented by Unseen Pro Ltd in order to ensure that only personal data is processed by default that is necessary for each specific purpose of the processing in terms of the volume of personal data collected, the degree of processing, the period of their storage and their accessibility, and the measures ensure that, by default, without intervention on the part of the individual, personal data is not accessible to an unlimited number of individuals.
Information about the personal data administrator:
Unseen Pro Ltd with its headquarters in Varna, Bulgaria. Company identificaiton number: BG200627122. Address for correspondence: 11 Otets Paisii Str., Varna 9000, Bulgaria.
Reason for collection, processing and storage of personal data:
Unseen Pro Ltd conducts electronic sales of tickets for cultural events (theatrical productions, cultural, entertainment and other events), carrying out this activity through a web-based platform: www.entase.bg.
In these cases, it collects and processes your personal data in connection with the provision of its services, namely: the conclusion and execution of contracts for the online sale of tickets for cultural events (theatrical productions, cultural, entertainment and other events), such as Unseen Pro Ltd. concludes the contracts on behalf and at the expense of the organizer of the cultural event.
When concluding and executing contracts for the sale of tickets, Unseen Pro Ltd. and the organizer of the event act as joint administrators of personal data with regard to the personal data collected and processed by them of users purchasing tickets.
Categories of personal data:
- First and last name;
- Phone number;
- Email address;
- Payment data and for the bank card - the type of card (Visa, MasterCard, etc.) and the last 4 (four) digits of its number, when the preferred payment option is payment by card / bank payment;
- Social status (retired/student/disabled) – when a special ticket purchased at a preferential price is issued.
Reason for collection, processing and storage of personal data:
- for the purpose and on the basis of the conclusion and execution of contracts for the sale of an ordered ticket for a cultural event, i.e. personal data are necessary for the conclusion and execution of the contract for the sale of tickets.
The legal basis for data processing is Art. 6, par. 1, letter "b" of the General Data Protection Regulation (EU) 2016/679 and art. 4, paragraph 1, item 3 of the GDPR.
The provision of personal data by the subject is a necessary requirement for the conclusion and execution of the contract, without which it is impossible for the contract to be concluded and executed.
- in order to fulfill the legal obligations of Unseen Pro Ltd. for accounting and tax reporting and declaration of tax obligations according to Bulgarian legislation (Law on accounting, the Corporate Income Tax Act, the Value Added Tax Act and other applicable regulations).
The legal basis for data processing is Art. 6, par.1, letter "c" of the General Data Protection Regulation (EU) 2016/679 and art.4, paragraph 1, item 1 of the GDPR.
The provision of personal data by the subject is a necessary requirement for the fulfillment of the legal obligations of the administrators for accounting and tax reporting and declaration of tax obligations, without which it is impossible to fulfill them.
The categories of recipients to whom the data may be disclosed:
In the execution of contracts for the online sale of tickets and the contract between Unseen Pro Ltd. and the organizers of the event and for the fulfillment of tax and accounting legal obligations, the categories of recipients are:
- the joint administrators - organizers of the cultural events for which tickets were purchased
- payment service providers - for the payment of the ticket;
- National Revenue Agency;
The legal basis for the transfer of personal data in these cases is Art. 49, Par. 1, letters "b" and "c" of Regulation (EU) 2016/679.
Terms and conditions for storage of personal data:
The terms for storing and deleting the users' personal data are determined depending on the purpose and basis for which they were collected.
A) The personal data that are processed for the purpose and on the basis of the conclusion and execution of the contracts for the purchase and sale of a ticket for a cultural event: until the completion of the execution of the contractual relations for the specific event.
B) The personal data that are processed in order to fulfill the legal obligations of Unseen Pro Ltd. for accounting and tax reporting and declaration of tax obligations according to Bulgarian legislation (Accounting Act, Corporate Income Tax Act, Value Added Tax Act and other applicable legal acts) are stored in the following terms:
- the primary accounting documents, including those for tax control according to the Tax Insurance Procedural Code (DOPK), are kept for a period of 5 years after the expiration of the limitation period for repayment of the public obligation, which is reported and certified with the relevant document;
- personal data in accounting registers and financial reports, if such are contained in them, are stored - 10 years according to the Accounting Law.
- personal data in all other media - 5 years according to the Accounting Law.
Rights of the subjects of personal data under Regulation (EU) 2016/679:
Every natural person whose personal data is processed by Unseen Pro Ltd has the following rights:
- right of access to the personal data related to the person, which are processed by the company/organization;
- right to correct or supplement inaccurate or incomplete personal data;
- right to erasure ("right to be forgotten") of personal data that are processed illegally or with a lost legal basis (expired storage period, withdrawn consent, completed initial purpose for which they were collected, etc.);
- right to limit processing - in the presence of legal dispute between Unseen Pro Ltd. and the individual until its resolution and/or for the establishment, exercise or defense of legal claims;
- right to data portability - if processed in an automated manner on the basis of consent or contract. For this purpose, the data is transmitted in a structured, widely used and machine-readable format. If it is technically feasible, the data can be transferred directly from Unseen Pro Ltd. to another administrator. The right to portability only covers data provided personally by the data subject, as well as personal data generated and collected by his activity.
- right to object - at any time and on grounds related to the individual's specific situation, provided that there are no compelling legal grounds for the processing that take precedence over the interests, rights and freedoms of the data subject, or a judicial process;
- right not to be subject to a fully automated decision involving profiling that gives rise to legal consequences for the data subject or affects him to a significant extent. Unseen Pro Ltd. does not use in its activities technologies that anticipate and allow the making of fully automated decisions, including profiling.
- the right to be notified in the event of a breach of the security of his personal data, in case, that the violation created a high risk for his rights and freedoms.
Procedure for exercising rights:
The subjects of personal data exercise their rights by submitting a request to Unseen Pro Ltd. The request can be submitted by mail or e-mail:
The data subject may submit a request for the exercise of his rights to any of the other joint controllers – event organizers.
Unseen Pro Ltd. shall consider the request and respond to the data subject by providing him with information on the actions taken by the company in connection with his request to exercise his rights, or if it has not taken action on the request of the data subject data, to inform him of the reasons for the refusal and of the possibility of filing a complaint with the Commission on the ZLD and seeking legal protection.
Unseen Pro Ltd. examines the request and responds to the subject without undue delay, but in all cases within a period of no longer than one month from receipt of the request. If necessary, this period can be extended by another two months, taking into account the complexity and number of requests. Unseen Pro Ltd. informs the data subject of any such extension within one month of receiving the request, indicating the reasons for the delay.
When the data subject submits a request by electronic means, the information shall be provided by electronic means whenever possible, unless the data subject has requested otherwise.
If the data subject has requested it, the information may be given verbally, provided that the identity of the data subject is proven by other means.
Consideration of subject requests, action taken and responses to subjects are provided free of charge. When the requests of a data subject are manifestly unfounded or excessive, in particular due to their repetition, Unseen Pro Ltd. may either:
a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the requested action, or
b) refuse to take action on the request. Unseen Pro Ltd. bears the burden of proving the manifestly unfounded or excessive nature of the request.
When there are reasonable concerns regarding the identity of the natural person submitting a request, Unseen Pro Ltd. may request the provision of additional information necessary to confirm the identity of the data subject.
Data subjects have the right to submit a complaint to the Commission for the Protection of Personal Data, the right to a judicial appeal against a decision or refusal or delay in considering his appeal by the Commission, as well as the right to bring an action before a court in cases where their rights are violated.