PRIVACY POLICY
SKYDIVE SOFIA Ltd. closely monitors the security and integrity of all personal data collected from our clients. We place the utmost importance on the lawful, fair, and transparent processing of personal data. The data provided to us is collected and processed solely for specific, explicitly stated, and legitimate purposes, and we do not process it further in a manner incompatible with these purposes. The data we collect and store is minimized and limited to what is necessary for the fulfillment of the purposes for which it was collected. We make every effort within our organization to ensure that your personal data is always accurate and up-to-date, and we rely on you to notify us of any inaccuracies so we can correct them promptly. We never store your data for a period longer than necessary for the purposes for which it is processed. We offer you the opportunity to withdraw your consent to the processing of your data at any time and without providing any reasons, as well as to request its deletion if you notify us of this wish. At the same time, it is our priority to process the data in a way that ensures an appropriate level of security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. We have implemented the necessary technical and organizational measures, as required by applicable legislation, to ensure the protection and security of our clients’ personal data.
SKYDIVE SOFIA Ltd. is the data controller and, in this capacity, complies with the provisions of applicable legislation (General Data Protection Regulation – Regulation (EU) 2016/679, the Personal Data Protection Act, and others).
DEFINITIONS
“Personal Data” refers to any information relating to an identified or identifiable natural person. Personal data includes, but is not limited to, name, personal identification number (PIN), email address, phone number, postal address, and more.
“Processing” means any operation or set of operations performed on personal data or a set of personal data, whether by automated or other means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making the data accessible, alignment or combination, restriction, erasure, or destruction.
“Controller” means any natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by EU law or the law of a Member State, the controller or the specific criteria for its designation may be laid down in Union law or in the law of a Member State.
Our privacy policy also outlines the options we provide for you to access, update, or otherwise control your personal data that we process. If you have any questions regarding our practices or any of your rights described below, you can contact our team at [email protected]. This inbox is actively monitored and managed.
WHAT INFORMATION WE COLLECT – PERSONAL DATA, PURPOSES, AND THE LEGAL BASIS ON WHICH SKYDIVE SOFIA Ltd. PROCESSES IT
At Skydive Sofia Ltd., we collect personal data necessary for providing our services, ensuring safety, and maintaining communication with our clients. The types of personal data we may collect include:
Identification data: Name, surname, personal identification number (PIN), date of birth, nationality, etc.
Contact details: Email address, phone number, mailing address.
Health-related data: Information related to your health and fitness, required for your safety during skydiving.
Booking and service-related data: Information regarding your bookings, participation in courses or jumps, preferences, etc.
Purpose for Data Collection – To establish contact with the client and send a voucher along with additional information.
Legal Basis for Processing These Personal Data – Explicit consent obtained from you as a client; taking steps to enter into a contract – by registering on the website www.skydivesofia.com, a contractual relationship is established, based on which we process your personal data.
2. Data Provided by the Client in the Declaration Prior to the Jump and for Contract Formation** – full name, date of birth, phone number, email, address.
Purpose for Data Collection: To fulfill the administrator’s obligations under the service contract for a parachute jump and to ensure the health and safety of the client during the jump.
Legal Basis for Processing These Personal Data – Fulfillment of the administrator’s obligation to provide the service.
Data for Issuing an Invoice – full name, personal identification number (PIN), address, email.
Purpose for Data Collection: We process these personal data to fulfill obligations arising from accounting and tax legislation. The tax and accounting laws of the Republic of Bulgaria require the preparation of certain financial and commercial information, including the storage of such information for a specified period, as well as any other data and documents relevant for tax purposes. In fulfilling this obligation, the relevant information and documents, which may contain personal data, are stored for the time periods prescribed by the applicable laws.
Legal Basis for Processing These Personal Data – Compliance with a legal obligation applicable to the company.
4. Data from Video and Photo Recording During the Jump – Such data is collected based on the explicit request and consent of the client, and is subject to an additional fee for the recording service.
Purpose for Data Collection: To fulfill the administrator’s obligations under the service contract for photo and video recording of the parachute jump.
Legal Basis for Processing These Personal Data – Fulfillment of the administrator’s obligation to provide the service.
With the explicit consent of the client, the data from the video and photo recording of the jump may:
– Be published on social media and/or on the Skydive Sofia website;
– Be used for promotional purposes to promote parachute jumps on social media, media outlets, and/or on the Skydive Sofia website.
Skydive Sofia Ltd. collects and processes personal data of professional skydivers who perform parachute jumps, namely:
1. Data provided by the skydivers in the **Declaration for Performing Parachute Jumps** – full name, personal identification number (PIN), date of birth, email, phone number, address, physical data (height, weight, blood type, allergies), full name, phone number, and email of an emergency contact person.
Purpose for Data Collection: To fulfill the administrator’s obligations under the contract for performing parachute jumps; ensuring the health and safety of the skydiver during the jump.
Legal Basis for Processing These Personal Data – Fulfillment of the administrator’s obligation under the contract for performing parachute jumps.
Data of minors is processed upon application and with the explicit consent of their parents or legal guardians.
Sharing/Disclosure of Personal Data
Disclosure of Personal Data
Skydive Sofia Ltd. does not share, sell, rent, trade, or transfer personal information collected from clients, except in the following cases:
1. Business Transfers – Your personal information may be transferred as an asset in connection with a merger, sale of the business, or as part of a corporate reorganization or other changes in corporate governance.
2. Service Providers – Personal data may be provided to service providers who assist us in delivering our services – such as couriers, accountants, system administrators, etc. However, no service provider will have access to the personal data stored by Skydive Sofia Ltd. without first entering into a data confidentiality agreement, which grants Skydive Sofia Ltd. the right to verify compliance with the obligations set out in the agreement.
3. Data Sharing with Trusted Partners – The collected personal information will only be shared with our trusted partners with whom we collaborate to organize and provide the services we offer. Before transferring any data, we ensure that these service providers offer sufficient guarantees that they apply appropriate technical and organizational measures to process the data in accordance with the requirements of the General Data Protection Regulation (EU Regulation 2016/679), the Bulgarian Personal Data Protection Act, the applicable secondary legislation, and our Privacy Policy, ensuring the protection of the data subject’s rights.
4. Minimization of Data – In accordance with the principle of data minimization, these providers will only receive the personal data necessary to perform their functions.
We are committed to ensuring that all third parties we share data with meet high standards of data protection and comply with all relevant legal requirements regarding personal data security and privacy.
Service providers are not allowed to retain personal data for their own or independent use, nor to keep it longer than necessary to perform the specified service.
We share personal data with the service provider when we have your explicit consent for this, or when there is another legal basis for doing so.
Lastly, personal data may be provided to state authorities (e.g., regulatory bodies and their subdivisions, authorities for crime detection and prevention), only when provided by law and under the conditions specified therein.
“SKYDIVE SOFIA” Ltd does not transfer/share your personal data with controllers and processors in countries outside the EU.
IV. TERM AND DURATION OF PERSONAL DATA PROCESSING BY “SKYDIVE SOFIA” LTD
“SKYDIVE SOFIA” LTD stores your personal data for no longer than necessary to fulfill the purposes for which they were collected, or until you withdraw your consent for processing. After the deletion of your profile or the withdrawal of your consent, “SKYDIVE SOFIA” LTD takes necessary measures to delete and destroy all your data without undue delay, anonymize, or pseudonymize them. “SKYDIVE SOFIA” LTD may pseudonymize personal data for statistical purposes, while adhering to all technical and organizational measures outlined in the General Data Protection Regulation – Regulation (EU) 2016/679, the Personal Data Protection Act, and other applicable laws, and ensuring compliance with the data minimization principle.
After pseudonymization, the processing of personal data in the registers maintained by “SKYDIVE SOFIA” LTD will not allow further association of the personal data with a specific data subject or identification of the data subject. As a result, the rights of data subjects under Articles 15, 16, 18, and 21 of the Regulation, specifically: the right of access, right to rectification, right to restriction of processing, and right to object, will not apply.
“SKYDIVE SOFIA” LTD stores your personal data provided in connection with the use of the service we offer for a period of 5 years for the purpose of protecting the legitimate interests of “SKYDIVE SOFIA” LTD in the event of legal or administrative disputes, with accounting documents being stored for the respective legally prescribed period.
“SKYDIVE SOFIA” LTD informs you if the retention period of the data needs to be extended in order to comply with a legal obligation, for the legitimate interests of the Administrator, or for any other reason.
V. YOUR RIGHTS REGARDING THE PROVIDED PERSONAL DATA
1. Right to Information
You have the right at any time to request information on whether your personal data is being stored, the purposes for which it is being processed, what categories of personal data are being processed, the recipients to whom your personal data has been disclosed, the retention period for which it will be stored, and whether automated decision-making and data profiling are taking place.
2. Right to Withdraw
If you have given consent for the use of your data, you can withdraw it at any time with effect for the future, without the need to provide any reasons.
You can send your request to withdraw your consent to the following email:
[email protected]
3. Right to Rectification
If you find that the data we hold about you is inaccurate, you can contact us to have it corrected.
4. Right to Erasure of Data
You have the right to request the deletion of your data without undue delay. We will delete it within a reasonable time once we confirm that no other legal grounds require its processing/storage.
After the deletion of your data, it will no longer be possible to provide information.
5. Right to Restriction of Processing
In certain cases, such as when you dispute the accuracy of your data or when we are verifying the grounds for its storage, you have the right to request that we restrict the processing of your personal data. During the restriction period, we may only store your personal data, and further processing activities will only be possible with your consent.
6. Right to Data Portability
If you request it, we will transfer or provide your data to you or another data controller in a structured, widely used, and machine-readable format. Direct transfer of the data will occur only if technically feasible.
7. Right to Object
You have the right to object at any time, and without providing reasons, to the processing of your personal data for the purposes of direct marketing, including profiling, as well as in cases where your data is processed based on the performance of a task in the public interest or when the processing is necessary for the purposes of our legitimate interests.
8. Right Not to Be Subject to a Decision Based Solely on Automated Data Processing, Including Profiling – “Skydive Sofia” does not engage in such data processing.
9. Right to Lodge a Complaint
You have the right to file a complaint regarding the processing of your personal data with the competent supervisory authority (in Bulgaria – the Commission for Personal Data Protection or the court), if you believe that your personal data protection rights have been violated.
**Commission for Personal Data Protection**
Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2
Information and Contact Center – Phone: +359 2 91-53-518
Email: [email protected]
Website: [www.cpdp.bg](http://www.cpdp.bg)
Contact:
**SKYDIVE SOFIA Ltd.**
Tax address and correspondence address:
Sofia, Lozenets District, Midjur St. 4
Phone: +359 888 84 08 42
Email: [email protected]
Website: https://skydivesofia.com