CONFIDENTIALITY DECLARATION
Your personal data and their confidentiality are important to you as physical persons as well as to Balkan Insurance Brokers JSC as a means of trust which you are giving us by providing these data.
We would like to inform you herewith what personal data, how and for what purposes Balkan Insurance Brokers JSC as Personal Data Administrator, collects, administers, keeps and shares, the measures undertaken for their protection and your rights in respect of your personal data administration.
This Declaration is drawn in accordance with the General Data Protection Regulation (Regulation (ЕU) 2016/679 – GDPR), referred to as “the Regulation” here on, which becomes effective 25.05.2018. At present Bulgaria applies the Personal Data Protection Act (PDPA).
As a physical person as per “the Regulation” and PDPA, you are a subject of personal data and Balkan Insurance Brokers JSC is a Personal Data Administrator who administers your personal data.
At the end of this document there are contact details written for contact with us as Personal Data Administrator.
This document could be amended and it is recommendable being periodically reviewed.
PERSONAL DATA BEING ADMINISTERED
As an Insurance Broker Company, Balkan Insurance Brokers JSC collects different data form you for the purpose of carrying out the insurance mediation appointed on your behalf for the arrangement and implementation of insurance contracts, which includes assessment and analysis of the insurable interest, obtaining proposals from the insurance companies for insurance policies arrangement, arrangement and administration of the insurance policies, claims handling assistance.
Balkan Insurance Brokers JSC as a Personal Data Administrator most often collect from you or the person representing you the following personal data, included in the insurance contract /policy/, which you would like to arrange:
· Names;
· ID number/Personal ID card number or Date of Birth;
· Address – permanent or correspondence address.
Depending on the type of insurance, Balkan Insurance Brokers JSC collects the following personal data:
· Family status;
· Property data: Vehicle, Immovable property: house, apartment, etc.;
· Gross salary data;
· Health status data.
For the purpose of contacting you and sending you and offer, notification or any other information, as well as in the cases when you make an order through our website or mobile application, Balkan Insurance Brokers JSC collects data in respect to:
· E-mail address;
· Mobile number or other telephone number;
· IP address;
„Balkan Insurance Brokers JSC” also collect the following personal data in regards to:
· Bank accounts, money origin;
· Video image – when visiting the offices as well as
· Any other information that you voluntarily give us in the process of our cooperation.
PERSONAL DATA COLLECTION REASONS
„Balkan Insurance Brokers JSC” collects the aforementioned data for one of the following REASONS:
· Contract: „Balkan Insurance Brokers JSC” concludes with you a written contract for insurance mediation appointment and collects personal data with respect to the conclusion and implementation of this contract. For certain insurances like the compulsory “Motor Third Party Liability”: a written Broker Appointment Contact is not required, the appointment is made orally.
· Law: „Balkan Insurance Brokers JSC “ has legislation obligations/tax, accounting for fraud prevention, terrorism financing, etc., and for their fulfillment there is an obligation to collect your personal data – as per the Law on Money Laundering Measures, Code on Taxation and Social Security, Law on Ownership, etc.
· Legitimate interest: „Balkan Insurance Brokers JSC “ has the right to exercise and protects juridical claims and this is an example of its legitimate interest and it is always estimated whether Your rights prevail over this legitimate interest.
· Сonsent: The consent must be explicit, voluntary, based on information awareness and is given on Your behalf in case of administration of your personal data, sending of information regarding insurance policies expiry and renewal, providing of additional services and products on behalf of Balkan Insurance Brokers JSC or its partners, which might be of interest to you and which could improve the quality of servicing. At all times You could terminate your consent and Balkan Insurance Brokers JSC will terminate your personal data administration in the future.
PERSONAL DATA PROTECTION PURPOSES
„Balkan Insurance Brokers JSC “ administers your personal data for one of the following PURPOSES:
· Providing services for insurance mediation for insurance policies arrangement: obtaining, analysis and sending offers from Insurance companies, insurance contract conclusion;
· Notification on circumstances under the insurance policies arranged on your behalf: legislation amendments, and other changes, payment due dates, insurance policies due dates and expiry;
· Claims handling assistance;
· Information on insurance products and services;
· Contacting you in regards to your objection or complaint;
· Complying with legal obligations and requirements as per the Bulgarian and European Union legislation;
· Improvement of the quality of services provided by „Balkan Insurance Brokers JSC “;
· Guaranteeing the security of the clients and employees of „Balkan Insurance Brokers JSC “, including personal data as well as the property in our offices;
· Exercising the protection of legal claims of „Balkan Insurance Brokers JSC “ in court.
PERSONAL DATA ACCESS AND SHARE:
Access to Your personal data for some of the aforementioned purposes could be possessed by:
· Public Authorities – Courts, Prosecution Department, National Security Bodies, Regulatory Authorities: Commissions, etc.
· Insurance companies selected on your behalf for the insurance policies arrangement;
· Accountants, Auditors, Lawyers;
· IT Providers and Specialists, Suirveyors, Post, incl. E-mails;
· Physicians, Hospitals, Road Assistance Service, Vehicle Workshops;
By contacting „Balkan Insurance Brokers JSC “ through its website or mobile application it is possible for you by links located there, to connect with other service providers’ websites. „Balkan Insurance Brokers JSC “ is not liable for the security of your personal data in case your data are being collected when you visit these other service providers’ websites. With the Partners with which „Balkan Insurance Brokers JSC “ has contracts Your Personal Data Protection terms have been agreed and „Balkan Insurance Brokers JSC only shares Your Personal Data, which are necessary for rendering the particular service.
The Insurance Companies which you have chosen for the arrangement of Your insurance policies, administer Your personal data separately from „Balkan Insurance Brokers JSC “ and for their purposes as Personal Data Administrators.
TRANSMISSION OF DATA IN ANOTHER COUNTRY
Without your consent, „Balkan Insurance Brokers JSC “will not transmit Your data in another country, member of the EU or a third country. The transmission of data necessary for providing an intermediary service for the arrangement of insurance (for instance with an insurance company, whose headquarters is in another country and it does not perform activity in Bulgaria through a branch or a right of settlement), will be carried out by complying the legal rights and with Your consent.
KEEPING OF DATA
„Balkan Insurance Brokers JSC “ keeps your data for a period in accordance with the purposes with which they were collected but for no less a period than that of the insurance policy duration.
In compliance with a legal obligation, „Balkan Insurance Brokers JSC “ will keep your data for a period longer than the aforementioned. .
For the protection of its legitimate interest, namely exercising its claims in court or by other means till the time-limit of filing the claims, „Balkan Insurance Brokers JSC “ will keep Your data for a period no less than 5 years after expiry or termination of the contract concluded with You.
PERSONAL DATA PROTECTION MEASURES
„Balkan Insurance Brokers JSC “ applies many technical and organizational measures for the protection of Your personal data against unauthorized access, utilization or disclosure as encryption of links in personal data communication (SSL – Protocol); data are kept on servers equipped with reliable contemporary protection and security protocols; personal data access control by determination of access levels and distribution of the obligations regarding data administration; utilization of access passwords; limitation of the use of mobile devices such as /laptops, phones/ in the process of administration and keeping of personal data; applies measures for premises security and the places there, where personal data are kept; adopts internal acts – policies, rules and instructions for personal data protection; has appointed a responsible person for personal data protection, whose contact details are written at the end of this document; requires from its partners, service providers and other persons with which personal data are being shared, to apply the respective measures for personal data protection.
YOUR RIGHTS
1. A Right of access to your Personal Data and a right to receive the following information: for what purpose your personal data have been administered, what personal data, period for personal data administration;
2. A Right to request correction of your personal data for being inaccurate or not up-to-date as well as a right to file a claim within a Supervisory Body in case of refusal on behalf of Balkan Insurance Brokers JSC to amend Your personal data;
3. A Right to request from Balkan Insurance Brokers JSC to limit the administration of Your personal data, when:
3.1. the personal data are not accurate and in this case the administration limitation is for a period for which Balkan Insurance Brokers JSC must check the accuracy of the personal data;
3.2. the personal data administration is not right but you do not want them to be deleted, just to be subject to limited administration;
3.3. „Balkan Insurance Brokers JSC “ does not need the personal data anymore for the administration but these are needed for legal claims acknowledgement, exercise and protection;
3.4. You have objected the data administration and expect the verification whether the legal grounds of „Balkan Insurance Brokers JSC “ prevail over Your interest as a subject of data;
4. A Right to request Your personal data to be deleted without unnecessary delay („the right to be forgotten”) – „Balkan Insurance Brokers JSC “ to erase the personal data from all systems and records, where these are kept, including to notify all third party administrators, to whom these data were provided – when there is no legal ground for the administration continuation or when you have terminated your consent and there is no other legal ground for their administration or when Your legitimate interest prevails over the legal reasons of Balkan Insurance Brokers JSC or when their administration violated the legislation;
5. A Right to object the administration of Your person data on behalf of „Balkan Insurance Brokers JSC “ at any time and point out Your reasons for this – legal reason or their usefor the purpose of direct marketing;
6. A Right to file a claim against Your personal data administration or not complying with Your rights in relation to Personal Data protection in front of the Competent Supervisory Body – Personal Data Protection Commission /CPDP/, address: Sofia 1592, Blvd Prof. Tzvetan Lazarov № 2, (www.cpdp.bg);
7. A Right to be notified when there is a risk of violation of the security of Your personal data and „Balkan Insurance Brokers JSC “ must inform you of the nature of the violation and what measures have been undertaken for its repairmen as well as to inform you whether the Supervisory Body was duly notified.
8. A Right of court or administrative protection in case Your rights in respect of Personal Data were violated;
9. A Right to terminate your consent for Personal data administration partially or totally at any time without affecting the legitimate administration as per Your consent before being terminated for which you will notify „Balkan Insurance Brokers JSC “ in the following way: written notification to: Sofia, Klokotniza 2A, IVEL Business Centre, fl. 9, office 26 or by e-mail: velev@zbkbalkan.com;
10. A Right of Data transfer – receipt on Your behalf and transfer to another party: for instance: another Insurer.
You can turn to „Balkan Insurance Brokers JSC “ at the below mentioned addresses and contact information in view of exercising Your rights.
When you require Personal Data Access, we will provide a copy and in case of a second or third request, we can determine a reasonable tax. „Balkan Insurance Brokers JSC “ could provide you the information in a widely used electronic format.
Transfer of Data could be done in the present of the following conditions:
Automatic administration of data and the reason is Your consent, Contract, or steps undertaken as per Your request before a contract conclusion. The Data transfer does not lead to their deletion and „Balkan Insurance Brokers JSC “ will continue administering them and providing you with a mediation service.
We will respond to every request in the form in which it was made: on paper or electronic format.
PERSONAL DATA ADMINISTRATOR CONTACT DETAILS
„Balkan Insurance Brokers JSC “, ID 175405608, headquarters: Sofia, Klokotnitza 2A Str., IVEL Business Centre, fl. 9, office 26.
The designated responsible person for Personal Data Protection at „Balkan Insurance Brokers JSC “ is Yordan Velev.
Request, objections and others could be addressed to the aforementioned address or to e-mail: velev@zbkbalkan.com, or mobile: тел. 0888602681.