What is personal data?
According the General Data Protection Regulation (“GDPR”), personal data is defined as:
“Any information related to an identified or identifiable natural person (“Data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Why does IBG Real Estates collect and store personal data?
In order to provide you with our services, such as preliminary information and consultations regarding properties in Bulgaria, mediation in the course of purchase, sale or rent of a real estate property, assistance with the preparation of the required documents and notarization of the deal, as well as after-sale services, we need to collect your personal data.
This data serves for the purpose of our correspondence with you prior to signing a contract, or for the purpose of us providing any information you require, identification prior to signing a mediation contract, in the course of preparing documents related to rental, purchase or sale contracts, marketing activities or advertisement.
We guarantee that the information we collect and use is essential for one or more of the above said purposes and does not aim at damaging your privacy or the inviolability of your personal life.
By providing us with your contact details voluntary you consent to receive marketing or advertising communication from IBG Real Estates.
What categories of personal data we collect and process?
The categories of personal data, we process are as follows: your full name, phone number, email, date and place of birth, citizen identification number, permanent and present address, data from your photo ID document – number and date of issue, bank account details, IP address.
The special categories of data we process are as follows: marital status and details regarding any existing marriage.
Your personal data, as our clients, we receive online or offline, on the grounds of your voluntary consent, on the basis of a contract between you and us, when required by law. By sending us the data explained above to our email or given to us on the grounds you consent that we collect and use the data. The personal data we collect will be used solely for one or more of the following purposes:
• In order to provide information you required;
• Preliminary correspondence before signing a contract;
• Signing a mediation contract;
• Identification in the course of preparing documents for the signing of a preliminary or official contract;
• Identification in the course of preparing documents for the purpose of signing a rental or purchase/sale contract;
• Marketing and/or advertising information;
• Preparing personalized advertisements, remarketing and measurement of results
The grounds on which we are entitled to process your personal data is: Your consent; implementation of a contract with you or our intent to enter into such contract; the processing is also required to comply with a legal requirement of ours or for the purpose of protecting your interests or third party interests, as well as to protect our own legitimate interests. The following organizations may receive your personal data (provided it is necessary):
• The banking institution working with us on your sales-purchasing property process;
• The lawyer we work with regarding your transaction – sales-purchasing property process;
• The notary public we work with regarding your transaction- sales-purchasing property process;
• The translator we work with regarding your transaction - sales-purchasing property process;
• The insurance company we work with regarding your transaction – after sale services;
• The currency broker we work with regarding your transaction - sales-purchasing property process;
• Our accounting company - sales-purchasing property process and after-sale services;
• Our partner offices - sales-purchasing property process;
• Google, Facebook and other advertising networks and platforms - in connection with sales-purchasing property process
You may withdraw your consent at any time, by submitting a withdrawal of consent for the processing of personal data and email it to firstname.lastname@example.org or as a paper copy, at any of our offices.
Transfer of personal data to a non-EU country or to an international organization
We do not intend to transfer your personal data to third parties without informing you in advance and securing your relevant consent.
Data retention period:
IBG Real Estates will store your personal data in the following manner: as a paper copy and/or online in its information database for the following duration:
• All documents, related to the preparation of signing a real estate transaction – 5 years
• All documents, related to the notarization of the transaction before a notary – 10 years
• All documents, data and information collected as required by the Law for Measures Against Money Laundering – 5 years
Your rights as Data subject are as follows:
At all times while we collect or process your personal data, you, in your capacity of Data subject, have the following rights:
• You may require a copy of your personal data from IBG Real Estates and right to access your personal data at any time;
• You are entitled to request from IBG Real Estates to provide you with your personal data in a manner suitable for transfer to another personal data controller, or to ask us to do it for you without any hindrance from us;
• You are entitled to request from IBG Real Estates to correct, without any undue delay, any of your personal data that is inaccurate, as well as any data, that is no longer up-to-date;
• You are entitled to request IBG Real Estates to delete your personal data at any time by sending your request to email@example.com
• We are entitled to refuse to delete your personal data on one of the following grounds:
– for the purpose of our compliance with a legal requirement or the performance of an assignment in public interest,
– while exercising official powers which were granted to us by you for the purpose of the specific entering into a real estate transaction;
– for the purpose of archiving in public interest, for statistical purposes, as long as a deletion would seriously impede or make impossible the achievement of the purposes of this processing;
– or for the establishment, exercising or protection of legal claims.
• You are entitled to request from IBG Real Estates to restrict the processing of your personal data, and in such case the data will only be stored, but not processed. Our refusal to restrict such processing will only be provided in writing and we are under obligation to motivate such refusal with a lawful reason;
• You are entitled to withdraw your consent for the processing of your personal data at any time with a specific request sent to IBG Real Estates;
• You are entitled to object against specific types of processing, such direct marketing (unwanted advertising messages);
• You are entitled to object against the automated processing, including profiling;
• You are entitled to not be subject of decision based solely on automated processing, including profiling;
• In case we need to use your personal data for a new purpose not part of the present notification of confidential treatment of personal data, we will serve you a new confidentiality notice and when and where necessary, we will ask for your consent for such new processing.
You are entitled to submit a complaint to the supervisory authority:
You are entitled to submit a complaint directly to the supervisory authority being:
Personal Data Protection Commission
Address: Sofia - 1592, Boulevard "Professor Tsvetan Lazarov" 2
In case you wish to submit a complaint regarding the processing of your personal data through IBG Real Estates , you can do so using the contact details of IBG Real Estates or directly to firstname.lastname@example.org
How we use your personal data?
The present confidentiality notice describes in detail the purposes and reasons for the collection and processing of your personal data, including the use of “cookies”.
We will not sell your personal data to third parties, and we will not transfer them in order to acquire any benefit. If necessary, IBG Real Estates, can transfer your personal data to our subcontractors, which have signed an appropriate contract with us. All third parties that can receive your data have undertaken before us the obligation to protect your data in a safe, reliable manner and to use it only for the purpose of performing the obligations they undertook before us. When they no longer need your data to perform their obligations they will have detailed instructions regarding the deletion of your personal data. When it is necessary to provide special personal data to a third party, we will only do so after obtaining your consent (unless the law requires otherwise). The recipients of your data can also be state bodies such as the National Revenue Agency, the National Insurance Institute, National Statistical Institute, Local Tax Authorities, Register Agency, and such data is provided to them in compliance with specific and clear legal obligations.
How we store and protect the personal data we collect?
IBG Real Estates will process (collect, store and use) the information you provided in a manner consistent with the General data Protection Regulation and the Personal Data Protection Act applicable in Bulgaria. We will always aim to maintain the information accurate and up-to-date. We will not store your information longer than necessary for the completion of the specific purposes it was collected for and of which you have been notified herein. Some of the information retention periods are subject to legal requirements for keeping documents and information for minimal periods of time, such as the Accounting Act or the Law for Measures against Money Laundering. We will undertake all possible technical and organization measures to ensure the protection of your data from unauthorized access, such as encryption, anonymization, masking and deletion after the expiry of the retention period.
How can you find out what personal data we have about you and how we process them?
Send us an email request to email@example.com and the responsible person from IBG Real Estates will provide an answer regarding what personal data we store and the manner of their processing.
How can you obtain access to the data of yours that we process?
You need to send us email request asking us to obtain access to your personal data
To certify your identity you will need to: indicate your full name and email address, as well as to confirm your email address by sending us your request from your own email.
For any questions please feel free to contact us at: firstname.lastname@example.org or call +359 878 466 690 – Desi Dimitrova, or visit any of our offices.