PRIVACY POLOCY OF “OMEKA MANAGEMENT” OOD
In accordance with the principle of transparency and Regulation No. 679/2016 by “OMEKA MANAGEMENT” OOD as a personal data administrator, we provide you with information on how we use, share and store your personal data.
Who are we?
“OMEKA MANAGEMENT” Ltd. is a legal entity, registered in the Trade Register and State Register of Trade and Industry with EIK 200325259, registered office and management address in the city of Sofia, 4 “Professor Velizar Velkov” Street, office 5-6.
How can you contact us?
You can contact us in a preferred and convenient way for you, namely: by email – office@omeka-management.com, as well as by phone +359 2 426 3126. If you prefer to meet with a representative of the Administrator, you can arrange a meeting by sending an e-mail or calling the indicated phone number and visit us at the address Sofia, Professor Velizar Velkov Street No. 4, office 5-6.
To whom do these Transparency Rules apply?
The rules on transparency in the processing of personal data refer to:
Property owners to whom “OMEKA MANAGEMENT” OOD provides condominium management services;
Counterparties;
Job/internship candidates;
Website visitors.
OWNERS OF PROPERTY TO WHICH SERVICES ARE PROVIDED
UNDER CONDOMINIUM MANAGEMENT
“OMEKA MANAGEMENT” Ltd. provides condominium management services to owners of individual units in a building /hereinafter referred to as “owners”/. In this regard, it processes their personal data, but not sensitive data.
What data do we collect about owners?
The data we collect about owners are: names; contact details: permanent or current address, e-mail address, telephone; bank account details.
How do we collect personal data about owners?
The way in which we collect the personal data of the owners is from themselves or from the manager (representative) of the condominium, who has entered into a condominium management contract or who wishes to enter into one.
Purpose of processing the personal data of the owners?
“OMEKA MANAGEMENT” Ltd. processes personal data of the owners in fulfillment of its contractual obligations or for the purposes of concluding a contract.
In certain cases, we process personal data in order to protect our legitimate interest or to fulfill an existing legal obligation.
On what basis do we process the personal data of the owners?
The basis for processing your personal data is the performance of a contract or conducting negotiations for the conclusion of one. Exceptionally, it is permissible for the basis for processing your personal data to be the Administrator’s legitimate interest or consent.
Exceptionally, we may process your personal data on the basis of an existing legal obligation.
To whom do we provide the owners’ personal data?
“OMEKA MANAGEMENT” OOD provides personal data to the owners of third parties when it is obliged to do so by law / eg. of the NRA, the Ministry of the Interior and other state bodies/. “OMEKA MANAGEMENT” Ltd. provides personal data to protect its legitimate interests to third parties – counterparties / eg. of lawyers or law firms to collect the company’s claims/. Data are also provided to processors of personal data under processing contracts / e.g. of an accounting firm/.
For how long do we store the personal data of the owners?
Owner data is stored for a period of 5 years after termination of the contract. The data contained in accounting documents and records are stored for financial and accounting purposes for a period of 10 years, starting from January 1 of the accounting period following the accounting period during which the obligation became due.
CONTRACTORS
Counterparties are data subjects with whom “OMEKA MANAGEMENT” OOD agrees to carry out certain actions outside the main activity of the company.
What personal data do we collect?
The data we collect for our counterparties is from the category of ordinary personal data and is only necessary for the purposes of fulfilling the existing contract between us and complying with the requirements of the applicable legislation.
How do we collect the personal data of our counterparties?
The personal data of the counterparties of “OMEKA MANAGEMENT” OOD is collected directly from the counterparties. It is possible that the processing of personal data of counterparties is carried out on the basis of contracts concluded through online platforms or email correspondence.
For what purpose do we process the personal data of our counterparties?
If you are our counterparty, the purpose for which we process your personal data is to conclude a contract or to fulfill an already concluded contract, as well as to fulfill an existing legal obligation for “OMEKA MANAGEMENT” OOD. Exceptionally, the purpose may be to satisfy the legitimate interest of the administrator or a third party.
On what basis do we process your personal data?
The basis for processing your personal data is the existing pre-contractual or contractual relationship or performance between us
of legal obligation. As an exception, it is permissible to process your personal data based on the legitimate interest of the Administrator or a third party.
Who do we share your personal data with?
“OMEKA MANAGEMENT” Ltd. provides the personal data of its counterparties to third parties only if this is necessary for the conclusion or execution of an already concluded contract (e.g. bank, courier, etc.), as well as if the latter is necessary for the fulfillment of a legal obligation ( NRA, etc.).
For the purposes of the accounting services of “OMEKA MANAGEMENT” OOD, your personal data is provided to an external accounting firm.
“OMEKA MANAGEMENT” Ltd. does not intend to transfer your personal data to a third party and/or an international organization.
For how long do we store our customers’ personal data?
The storage of counterparty data in connection with the performance of the contract is for the applicable limitation period, and the tax and accounting documents are stored for a period of 10 years, starting from January 1 of the accounting period following the accounting period during which the obligation became due.
WEBSITE VISITORS
What personal data do we collect about site visitors?
“OMEKA MANAGEMENT” Ltd. does not collect personal data of website visitors. When someone visits the Administrator’s site, the information that is collected is related to visitor behavior patterns. We do this to detect the number of visitors to different parts of the site. This information is only processed in a way that does not identify the subject. We make no attempt to understand the identity of visitors to our website.
In case you send an inquiry through the contact form on the site, your personal data will be sent directly and only to the email of “OMEKA MANAGEMENT” OOD and will be processed according to the nature of the inquiry (For example: if it is for the provision of services under a condominium management contract, is processed in the above ways for processing owner data).
CANDIDATES FOR JOB/INTERNSHIP
When applying for a position at “OMEKA MANAGEMENT” OOD, documents containing personal data are submitted. The processing of the latter is carried out in accordance with the Law on the Protection of Personal Data and the General Regulation on the Protection of Personal Data.
What personal data of yours do we process?
The personal data we collect about job/internship applicants is only necessary to determine the applicant’s competence and future inclusion in the team.
How do we collect your personal data?
The collection of personal data of job/internship candidates is based on documents sent by them – resume/CV, cover letter, certificates, diplomas, etc., as well as copies thereof.
For what purpose do we process your personal data?
The purpose of processing your personal data is human resource management, financial and accounting activities and is justified by our general desire to conclude a contract.
On what basis do we process your personal data?
The basis for processing your personal data is pre-contractual relations aimed at concluding a contract for employment or internship.
How long do we keep your personal data?
The personal data provided in the recruitment process are stored for a period of 6 months from the end of the selection procedure.
After the expiration of the period under the previous paragraph, the data is destroyed or deleted.
In the event that, during a selection procedure, original documents or notarized copies of documents certifying the physical and mental fitness of the candidate, the necessary qualification level and experience for the position are presented, the data subject may request within 6 months from the final completion of the selection procedure to receive back the submitted documents.
To whom do we provide the personal data of job/internship candidates?
The data of job/internship candidates at “OMEKA MANAGEMENT” OOD are not provided to third parties.
PROCESSING OF PERSONAL DATA BASED ON CONSENT
In the event that personal data of any of the above categories of persons is processed on the basis of consent, prior written and explicit consent for the purposes of processing is required.
Consent can be withdrawn at any time without affecting the provision of services.
RIGHTS OF DATA SUBJECTS
In relation to the processing of your personal data, it is important for us to inform you that you have a set of rights that you are free to exercise whenever you deem necessary by contacting “OMEKA MANAGEMENT” OOD in its capacity as a personal data administrator with the corresponding request.
The right of access
What is the right of access to personal data?
Based on the right of access, we inform you whether we process your personal data, what categories of personal data we process and in what way, on what grounds we do so, for what period we will process them, as well as whether we provide them to other persons.
Do we always have to grant your request?
Access can be denied if your request is clearly unfounded.
Access may also be denied if your personal data contains personal data of third parties, unless the third parties have expressly consented to us providing their data to you.
What will you get in response to your request?
In the event that we consider that your request is justified and its satisfaction would not affect the personal data of third parties (or their consent is available), you will receive a response that contains information according to the above criteria.
If there is a reason for refusal, we will provide you with information about the reason for refusal.
Correction of personal data
What is the right to rectification to personal data?
The right to rectification of personal data enables the correction of inaccurate or no longer relevant data.
You can also use this right in cases where it is necessary to complete your personal data in view of the purposes for which they were provided to us.
How can you exercise your right to rectification of personal data?
You can exercise your right to correct the personal data processed by “OMEKA MANAGEMENT” OOD by submitting a request. You can use the form available on the Administrator’s website or submit a request in free text.
In the application for correcting or supplementing the data, you need to indicate which particular data you consider to be incorrect, how they should be corrected or supplemented, as well as attach relevant evidence, if available.
What will you get in response to your request?
In the event that we determine that your request should be granted, we will take the necessary steps to correct your personal data in the manner in which you have stated that this should be done.
If there is a reason for refusal, we will provide you with information about the reason for refusal.
Delete personal data
What is the right to erasure of personal data?
The right to erasure of personal data, or more widely known as the right to be forgotten, gives you the opportunity, after your personal data are no longer necessary for the purposes for which “OMEKA MANAGEMENT” OOD collects and processes them, to request from the Administrator that they be deleted.
When can you request your personal data to be deleted?
You can exercise your right to have your personal data deleted if:
your personal data is processed based on your consent and you decide to withdraw it;
you no longer wish your data to be processed for marketing purposes;
you believe that their processing is unlawful.
Will your request always be granted?
The right to be forgotten is not absolute, therefore “OMEKA MANAGEMENT” OOD reserves the right to refuse to satisfy your request if the processing is:
on a legal basis;
for the establishment, exercise and defense of legal claims;
for the purposes for which they were collected or otherwise processed;
for scientific, research and statistical purposes, as well as if it is carried out in the public interest.
Also, if your request is clearly unfounded, we reserve the right to refuse to delete your data.
What will you get in response to your request?
In the event that we refuse to grant your request, you will receive our reasons for this decision.
In case the conditions for satisfying your request are present, the same will be fulfilled.
Restriction of personal data processing
What is the right to restrict the processing of personal data?
The right to restrict the processing of personal data enables the data subject to restrict the way in which his personal data is processed if he doubts the accuracy of the data or the way in which it is used.
Does the right of restriction prohibit the controller from processing the personal data?
Exercising this right does not affect the Administrator’s right to process your personal data in any of the following ways:
to continue to store your personal data;
to use them for the establishment, exercise and defense of legal claims;
to protect the rights of others;
an important public interest requires this.
What is restriction of processing?
Usually, the restriction on the processing of your personal data is temporary, for the following periods:
– If you dispute the accuracy of your personal data – the processing of personal data is limited until it is clarified whether the request to correct them is justified;
– If you object to the processing of your data on the basis of public or legitimate interest – the processing of personal data is limited while the verification lasts, which will assess whose interest is of primary importance.
It is possible that the restriction is not temporary, but in relation to a certain type of processing.
If the restriction is temporary, the Administrator undertakes to inform you before it expires.
Is the data controller always obliged to comply with your request?
The administrator is obliged to satisfy your request if:
no longer needs your data
for the purposes of their processing, but you need them in order to establish, exercise or defend legal claims;
you believe that we are processing your data unlawfully, but you still do not want it to be deleted;
has provided your data to third parties, it undertakes, as far as this is possible and would not cost us a disproportionately large effort, to inform them of your request.
If we consider that your request for restriction is clearly unfounded, we reserve the right to refuse to restrict the processing of your data, informing you of our reasoned refusal.
Portability of personal data
What is the right to data portability?
“OMEKA MANAGEMENT” Ltd., as a personal data administrator, provides the opportunity to exercise your right to portability of personal data in cases where your personal data is processed in an automated manner, based on your consent or the processing is necessary for the fulfillment of a contractual obligation. Based on this right, you will be able to receive your personal data or have them directly transferred to another Personal Data Administrator selected by you.
You have the right to request to receive your personal data in a structured and widely used, machine-readable format and to transfer it to another controller or, where technically feasible, to request that we directly transfer it to a controller you designate.
Is the data controller always obliged to comply with your request?
The right to data portability is not absolute. The right to portability of personal data is applicable in cases where:
the processing is based on consent or is necessary to fulfill a contractual obligation, and
automated processing of personal data is available.
What happens to my personal data after the data portability request is granted?
The administrator does not delete your personal data, but stops processing it for the purposes for which it was provided.
Objection to processing of personal data
What is the right to object to the processing of personal data?
The right to object gives you the opportunity to object to the processing of your personal data for certain purposes.
Can you always object to the processing of your personal data?
You can object to the processing only in cases where the Administrator processes them:
on the basis of the existence of a legitimate interest, regardless of whether this is the legitimate interest of the Administrator of personal data or of a third party;
for the purposes of scientific or historical research or for statistical purposes;
for direct marketing purposes (including profiling).
Exercise of rights
How can you exercise the rights listed?
You can exercise any of the listed rights by submitting a written request to the Personal Data Administrator.
How is the request submitted?
For this purpose, you can use the application form for the relevant right or submit a request in free text.
Where is the application form?
The form is available at the Administrator’s office at Sofia, 4 “Prof. Velizar Velkov” str., offices 5 and 6 or on the Administrator’s website – www.omeka-management.com
What should the free text request contain if you prefer to contact the Administrator in this way?
In your request, you need to indicate your name and address, as well as other identifying data if you consider it necessary, a description of your request, the preferred form of communication, date and signature.
If you are acting as an authorized person, you must attach the corresponding power of attorney to the application.
Where is the request submitted?
You can submit the request in person at the office of “OMEKA MANAGEMENT” OOD at the address Sofia, 4 “Prof. Velizar Velkov” Str., offices 5 and 6, as well as submit it by courier or by mail to this address.
You can submit your completed application or request in free text and by email: office@omeka-management.com
How will you know the outcome of the submitted claim?
We will contact you in the way you indicated – email or address. In the event that you do not explicitly indicate a method of communication – e-mail or address, the Administrator will contact you in the way he deems most convenient in terms of efficiency. If you have provided only an email or only an address, we will contact you using the communication method you provided.
Can I be asked for additional documents/data?
In order to protect the rights of the data subject, you may be asked for additional documents or data to ensure that there is no abuse of rights. The requested additional data or documents will not be processed in a manner, by means and for purposes other than identifying the data subject and the person making the request to exercise rights.
How long will you wait for a response?
“OMEKA MANAGEMENT” Ltd. is a personal data administrator with a high commitment in the field of personal data protection, which is why we make efforts to respond to requests as quickly as possible. Despite that, we inform you that the legally established term is up to 1 month from the submission of the application.
PROTECTIVE EQUIPMENT
What to do if you are not satisfied with the Administrator’s answer or think that your rights have been violated?
If you believe that your rights under Regulation 2016/679 and under the Personal Data Protection Act have been violated, you have the right to refer the Personal Data Protection Commission.
The committee will review your case and inform you of the outcome.
After issuing a decision, the Commission will send you a copy of it, which you have the right to appeal in court according to the rules of the Administrative Procedure Code.
Along with this, you have the opportunity to appeal to the relevant administrative court or the Supreme Administrative Court according to the rules set out in the Code of Administrative Procedure.
You cannot refer to the court if there is a pending proceeding before the Commission for the same violation or its decision regarding the same violation has been appealed and no court decision has entered into force.