INTRODUCTION

"V PARK VARNA" EOOD ("V-Park") respects the privacy of its customers and guarantees the maximum protection of their personal data. This Privacy Policy and Personal Data Protection (hereinafter referred to as the "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection. This Privacy Policy regulates the processing of personal data of individuals or representatives of legal entities of our customers or potential customers, as well as users of our website: www.varna-airport-parking.eu (the "Site"), in connection with the services provided by "V PARK VARNA" EOOD, including those provided through and accessible on the Site. This Privacy Policy, together with the General Terms and Conditions of Use of the Website, the Cookie Policy and any other documents mentioned on the Site, sets out the rules that “V PARK VARNA” Ltd. will follow when processing personal data that we collect from you or about you, or that you provide to us. This Privacy Policy does not affect, limit or revoke your rights arising from the Personal Data Protection Act (“PDPA”) or other relevant legislation. If you have any questions or comments regarding this Privacy Policy, please contact us at: varna.airport.parking@gmail.com. Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing your Personal Data you agree to its terms. If you do not want us to process your personal data in the manner described in this Privacy Policy, please do not provide it to us. The provision of personal data by you is voluntary, in view of the use of certain services provided by us and the use of the Site and/or access to it, as well as in view of online reservations on the Site. Please note that in some cases we will not be able to provide you with the service you have requested if you do not provide us with the necessary information. Please also note that in certain cases your consent to the processing of personal data may not be necessary if “V PARK VARNA” EOOD has another legal basis, e.g. fulfillment of statutory obligations.

COOKIES

“V PARK VARNA” EOOD uses cookies on its website (www.varna-airport-parking.eu) in order to offer personalization to users and collect information about the use of the website. Cookies are small text files that are stored on your computer or device when you visit a website. They can be used to store information that is used to coordinate between different sections of the website, such as a shopping cart or personalized pages. These cookies help “V PARK VARNA” EOOD provide a better user experience by adapting to their preferences and needs.

Through the use of cookies, “V PARK VARNA” EOOD may collect certain information about you, such as your preferences, and use it to improve the functionality and personalization of the website. This may include remembering your choice of language or region, preferences for displaying certain content, or convenience settings.

It is important to note that cookies do not store personal information that can directly identify you. All information collected by cookies is anonymous and is used solely for the purpose of improving the functionality of the website.

If you do not wish to allow the use of cookies, you can change your browser settings and refuse to accept cookies. However, you should keep in mind that this may limit the functionality and convenience of the website.

By visiting and using the website of "V PARK VARNA" EOOD, you express your consent to the use of cookies in accordance with this Privacy Policy. For more information about the use of cookies and how "V PARK VARNA" EOOD processes personal data, you can read our Privacy Policy.

INFORMATION ABOUT THE PERSONAL DATA ADMINISTRATOR

• Name: "V PARK VARNA" EOOD
• UIC/BULSTAT: 208279689
• Head office and address of management: Varna, Odesos district, 24 Kosta Tyulev Str., 6^th floor
• Correspondence details: Varna, Odesos district, 24 Kosta Tyulev Str., 6^th floor
• Email: varna.airport.parking@gmail.com
• Telephone: +359 893 833 839

INFORMATION ABOUT THE COMPETENT SUPERVISORY AUTHORITY

1. Name: Commission for personal data protection
2. Head office and address of management: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
4. Phone: +359 2 915 3 518
5. Email: kzld@government.bg, kzld@cpdp.bg
6. Website: www.cpdp.bg

CATEGORIES OF PERSONAL DATA THAT "V PARK VARNA" EOOD COLLECTS AND PROCESSES.

1. "V PARK VARNA" EOOD may process various categories of personal data, which may include publicly available data or information provided by you. The main types of personal data processed are:

• Personal identification information (e.g. name, email address, preferred language of communication, etc.);
• Contact details (including postal and email addresses, telephone number or preferred contact method);
• Financial information (e.g. bank account, etc.);
• Information about a representative (legal representative or proxy of a client-legal entity);
• Data related to the profile on the website (such as name, address, telephone number, date of birth, etc.);
• Data related to the conclusion of contracts, sales and other services with individuals or legal entities (including names, personal identification number, etc.).

2. "V PARK VARNA" EOOD may collect and process data that is generated and created by the company itself in the process of providing the services:

• Data about the use of your device, including its type, operating system, IP address and location;
• Your preferences regarding the services provided;
• Communication between you and the company, your preferences, complaints and others;
• Information about your visits to the website and the way you use it, including the history of your choices;
• Data required by law or to fulfill regulatory obligations;
• Video recordings of visits to the parking lot or office, audio recordings of calls to the contact center;
• Photos or videos taken when participating in games or promotional campaigns.

3. In order to ensure high quality of services and compliance with obligations under client contracts, "V PARK VARNA" EOOD has the right to process information that is available in public registers, as well as information provided by third parties, in accordance with legal provisions.

4. "V PARK VARNA" EOOD has the obligation and right to verify the accuracy of the data recorded in the database. In this context, you may be required to confirm or correct the information provided.

5. Different types of personal data can be processed both independently and in combination with each other.

USE AND STORAGE OF PERSONAL DATA

1. Processing of personal data that is necessary for the conclusion and performance of contracts with us or in connection with the preparation for the conclusion of contracts with us.

"V PARK VARNA" EOOD processes your data for the following purposes:

• Identifying a client when concluding a new or changing an existing contract, providing explanations about the services used and executing a concluded contract.
• Preparing contract proposals, sending pre-contractual information and contract drafts, managing pre-sales activities.
• Performing obligations arising from contracts concluded with you or with a company you represent, exercising rights and ensuring the execution of contracts by our clients.
• Reviewing and responding to client complaints, inquiries, appeals and claims.
• Technical assistance for creating an account(s) or recovering a forgotten password to access our website.
• Verifying your age for online reservations.
• Paying amounts due, managing collections of receivables.
• Managing and administering online reservations and payments.
• Renewing important information related to changes in our policy and other administrative information.

2. In fulfillment of its legal obligations, "V PARK VARNA" EOOD processes your data for the following purposes:

• Issuing invoices.
• Tax and social security inspections by the relevant competent authorities.
• Fulfillment of obligations related to off-premises sales, as provided for in the Consumer Protection Act.
• Providing information to the Personal Data Protection Commission in connection with obligations under the legal acts for the protection of personal data.
• Obligations related to accounting and the Tax and Social Security Procedure Code.

3. "V PARK VARNA" EOOD processes your data with your explicit written consent for the following purposes:

• Creating and managing a personal profile on our website, technical assistance for creating and recovering forgotten passwords.
• Direct marketing of products and services.
• Participation in surveys, gift games and promotional campaigns.

4. The processing is necessary for the purposes of the legitimate interests of "V PARK VARNA" EOOD:

• Protection of the property, interests and security of "V PARK VARNA" EOOD, its visitors and employees, through video surveillance.
• Assessment of user satisfaction and the effectiveness of the offered advertising.
• Analysis of the history of purchases, preferences and behavior of customers.
• Ensuring quality customer service through video recordings.

5. Categories of third parties that have access to and process your personal data:

• Security companies with a private security license.
• Persons who maintain equipment and software used to process your personal data.
• Debt collection service providers, notaries, lawyers and other third parties in the event of breach of contract.
• Banks processing your payments.
• Persons providing consulting services such as lawyers, accountants, marketing agencies, etc.
• Authorities, institutions and persons to whom we must provide data under applicable law.

PERIODS OF STORAGE OF YOUR PERSONAL DATA

The duration of storage of your personal data depends on the specific purposes for which they are collected:

1. Data for contractual relations: The personal data that we process for the purpose of concluding, amending and performing contracts between "V PARK VARNA" EOOD and you or the company you represent are stored during the period of validity of the contract and thereafter - until all financial relations between the parties are finally settled. In some cases, we may store parts of your personal data for a longer period after the expiration of the limitation period for repayment of obligations. This is done for the purpose of protection against possible claims of customers in connection with the conclusion or termination of contracts with us. Also, in the event of an already existing legal dispute, the data may be stored until its final resolution by a court or arbitration decision.

2. Accounting and financial data: The personal data that we process for the purpose of issuing accounting and financial documents for the needs of tax and social security control, such as invoices, debit and credit notes, service contracts, are stored for a period of at least 11 years after the expiry of the limitation period within which public claims can be claimed. This period may be extended if the applicable legislation provides for longer periods.

3. Direct marketing: The personal data that we process for the purpose of direct marketing will be stored until you clearly withdraw the consent given for this type of processing or object to the processing of your data for the needs of direct marketing.

4. Video recordings and telephone calls: Video recordings captured by security cameras are stored for up to 60 days from the date of creation of the recording. Telephone calls are stored for up to 360 days after they are made.

YOUR RIGHTS IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA

1. General rights

With regard to the processing of personal data, you have the following rights that you can exercise at any time while we are storing or processing your personal data. This can be done by sending a request to the address of "V PARK VARNA" EOOD mentioned above, or by sending an email to: varna.airport.parking@gmail.com

You have the right to request from "V PARK VARNA" EOOD:

• A copy of your personal data and access to them at any time.
• Correction of inaccurate personal data or data that is no longer up-to-date without undue delay.
• Transfer your personal data to another personal data controller or request "V PARK VARNA" EOOD to do so without hindrance (right to portability).
• Erase your personal data without undue delay where there is a legal basis for this.
• Restriction of processing of your personal data data, in which case your data will only be stored, but not processed. The refusal to restrict will be explicit and only in writing, with motivation according to legal requirements.

2. Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint directly with the supervisory authority. The competent authority for this is the Personal Data Protection Commission, address: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd. (www.cpdp.bg). If you wish to lodge a complaint regarding the processing of your personal data by “V PARK VARNA” EOOD, you can do so using the contact details provided by the administrator or the Data Protection Officer.

3. Automated processing and profiling

When visiting our website, we use automated processing to tailor our products and services to your needs in the best possible way.

4. Objection to direct marketing

You have the right to object to the processing of your personal data for direct marketing and advertising purposes, as well as to their disclosure to third parties and their use on their behalf for these purposes. You can withdraw your consent to this processing at any time by sending the relevant request to stop the use of your data for direct marketing purposes to the following address: varna.airport.parking@gmail.com

5. Possibility of refusing to provide personal data

In order to conclude a contract with you and/or provide the services you have requested, "V PARK VARNA" EOOD needs certain data to identify the contracting party, its authorized representative, contact and payment details. Failure to provide such data may prevent the possibility of purchasing and delivering services on your part. Similarly, when creating a profile on the website, certain data is mandatory in order to have access to the history of the services provided.

If you have additional questions or need further clarification, do not hesitate to contact us.

HOW WE PROTECT YOUR DATA

"V PARK VARNA" EOOD applies various organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and monitor its processing.

These security measures include:

• Approved internal procedures for processing, registration and storage of personal data, which are constantly monitored.
• Limited access of employees of "V PARK VARNA" EOOD to personal data and permission for processing in the database, in accordance with their duties.
• Confidentiality obligations imposed on employees.
• Limited access to office equipment and employees' computers.
• Use of all organizational and technical measures provided for in the Personal Data Protection Act, as well as the best international standards.
• Use of additional protection mechanisms such as encryption and pseudonymization, for maximum security in processing, transferring and storing data.

These security measures are constantly updated and adapted to the latest technological trends.

LINKS TO OTHER SITES

Sometimes our website may contain links to other sites. We do not control these sites and do not endorse their content, services and products. We recommend that you exercise caution and carefully review the content and terms of use of these sites. “V PARK VARNA” EOOD is not responsible for the privacy or content of such sites and we advise you to review their privacy policies. However, if you inform us of illegal activities or illegal information on such sites, we will take the necessary measures to remove links to them.

PERSONAL DATA FOR CHILDREN

We do not knowingly collect personal information from persons under the age of 16. If we determine that we have received personal data from a person under 16 years of age, we will take immediate action to delete such data or to obtain consent from the child's parent or guardian.

CHANGES TO THE PRIVACY POLICY

Please note that we may periodically update our Privacy Policy. In the event of changes to this policy, we will publish a notice on our website, as well as the updated Privacy Policy. All changes and additions to this policy will be applied only after the publication of its current version, accessible through our website.