NOTICE
TO CLIENTS OF “CAPITAL ESTATE” LTD, UIC: 202885833
REGARDING THE PROCESSING OF PERSONAL DATA
This notice is provided to the clients of “CAPITAL ESTATE” Ltd, UIC: 202885833, pursuant to Regulation (EU) 2016/679 (the General Data Protection Regulation – GDPR) and discloses information concerning the processing of personal data.
1. “CAPITAL ESTATE” Ltd, UIC: 202885833, is a company with its registered office and management address at: Burgas, 18 Vasil Aprilov Street, floor 1. The company is represented by the Manager – Ivan Ventsislavov Vasilev.
2. The company provides consultancy services in the field of real estate, including intermediation in the purchase and sale of properties, leasing, and management of residential, commercial, luxury real estate, and land.
3. The purposes of processing personal data are related to the identification of clients and counterparties, the assessment of the appropriateness and suitability of services, and compliance with statutory requirements established under the Measures Against Money Laundering Act (MAMLA) and the Measures Against Financing of Terrorism Act (MAFTA).
4. When establishing business relations with individuals, the Company, in accordance with Article 4, item 18 of the MAMLA, is obliged to identify its clients. Under this law, identification and verification are carried out through the presentation of an official identity document and by taking a copy thereof. This legislation requires the Controller to collect and process personal data of natural persons.
5. The Company has a legal right and obligation to process personal data of its clients for the purposes established in the MAMLA, the Tax and Social Insurance Procedure Code (TSIPC), the Accounting Act, their implementing regulations, as well as other directly applicable EU Regulations or subordinate legislation applicable in the Republic of Bulgaria. These acts impose obligations on the Company as a data controller, whose compliance is mandatory for the lawful performance of its activities and provision of related services, including the processing and storage of personal data.
6. The Company collects personal data of its clients through employees working under employment or civil contracts, or under other contractual arrangements, all of whom are bound by confidentiality agreements.
7. Recipients of personal data include state authorities to which the Company is legally obliged to provide the requested information, as well as legal counsels, lawyers, accountants, auditors, and risk managers. With the client’s consent, the Company may also provide personal data to its partners or providers of financial services.
8. In its capacity as a data controller, the Company does not intend to transfer personal data to a third country or to an international organization, unless the Client has provided explicit consent for such transfer.
9. The Company retains all collected and prepared documents, data, and information under the MAMLA, its Implementing Rules, and directly applicable EU regulations for a minimum period of 5 years.
For business relationships with clients or correspondent relations, the retention period starts from the beginning of the calendar year following the year in which the relationship was terminated. The legal basis for this period is established in Article 67 of the MAMLA.
10. The Client has the right to request from the Company access to or rectification of personal data, but the erasure or restriction of processing can only occur after the statutory retention period has expired. The Client also has the right to object to processing and the right to data portability, provided this does not conflict with any legal obligation of “CAPITAL ESTATE” Ltd or other applicable EU regulations.
11. Where the processing of personal data is based on consent, the Client has the right to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to the withdrawal.
12. The Client has the right to lodge a complaint with a supervisory authority regarding the processing of their personal data. Data subjects whose data are collected and processed by “CAPITAL ESTATE” Ltd may submit such a complaint to the Commission for Personal Data Protection (CPDP) at the following address:
1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd., tel. +359 2 91 53 518, reception hours: 9:00 – 17:30.
13. The provision of personal data is a statutory requirement under the MAMLA, TSIPC, Accounting Act, and other relevant legislation.
By signing this Notice, data subjects whose data are collected and processed by “CAPITAL ESTATE” Ltd are deemed informed that refusal to provide the required personal data under the MAMLA and its Implementing Rules constitutes a legal ground for the Company to refuse the requested service.
Consequences of refusal to provide personal data:
If “CAPITAL ESTATE” Ltd is unable to fulfill its obligations under the MAMLA due to a client’s refusal to provide personal data, the Company is legally obliged to refuse the transaction or the establishment of a business relationship.
“CAPITAL ESTATE” Ltd does not use automated decision-making, including profiling, and therefore does not provide information regarding any logic used or the significance and expected consequences of such processing for the data subject.
Contact details of the Data Protection Officer:
Ivan Ventsislavov Vasilev
· Address: Burgas, 18 Vasil Aprilov Street, floor 1
· Mobile: +359 889 904 410
· Email: [email protected]