TRAVENTURIA LTD is responsible for the personal data of its clients. Protecting your personal information is important to us. This protection is also governed by the Personal Data Act, which was replaced by the General Data Protection Regulation (GDPR) as of May 25, 2018. Below, you can read about how we process your personal data and what rights you have.

The purpose of this information is to inform the CLIENT and individuals using Traventuria LTD’s passenger transport services about the company’s General Terms and Conditions. The service is requested through the online system either by the client personally or for third parties related to the ordering party, on their behalf. Hereinafter, we refer to these individuals generally as “Clients.” When the CLIENT requests passenger transport services on behalf of and for the benefit of other entities, he provides personal data for them. The Client undertakes to bring these terms to the attention of those entities.

1. Categories of Personal Data Processed

Traventuria LTD collects and processes personal data to the extent necessary for the company’s operations to provide a high-quality service. When using the online reservation system for selling bus tickets for Traventuria LTD’s regular passenger transport lines, the following personal data are processed:

– identifying information: first and last name; date of birth; IP address;
– information for contacts: e-mail address; phone number;
– data related to client habits and preferences;
– data related to the use of services provided by Traventuria LTD (discount cards, promotional messages);
– data collected through client visits to Traventuria LTD’s websites;

Traventuria LTD uses on its web-based platforms, including the online reservation system for selling tickets, the so-called “cookies.” These are small files stored on the user’s disk that retain certain settings and data for communication with the system through the browser. Some of the “cookies” used by Traventuria LTD are deleted after the end of each browser session (so-called “session cookies”). Others remain on the device used to visit the system and enable the browser to be recognized upon a subsequent visit (so-called “persistent cookies”). This helps to properly build the website and allows Traventuria LTD to offer an easier way to use it. Different browsers, in their settings, allow users to introduce restrictions on the use and deletion of “cookies.” Refusing or restricting the use of “cookies” may hinder the use of the web services that Traventuria LTD provides, including the online system for selling bus tickets for passenger transport on regular lines of Traventuria LTD.

2. Grounds and Purposes for Processing Personal Data

Traventuria LTD collects, stores, and uses personal data for Clients based on one of the following grounds, in order to achieve one of the following purposes:

A) Fulfillment of legal and regulatory obligations
Traventuria LTD processes personal data for Clients to fulfill its legal and regulatory obligations related to the services provided, namely:
– carrying out transport on regular bus lines on the territory of the Republic of Bulgaria;
– compliance with legislation related to sanctions and/or security measures;
– response to an official inquiry from a duly authorized public or judicial authority;

B) Performance of a contract concluded with and in favor of Clients
Traventuria LTD processes personal data for the conclusion and performance of transport contracts and the fulfillment of its rights and obligations under these General Terms and Conditions such as:
– establishing relations with new Clients;
– concluding, amending, performing, and terminating contracts;
– providing discounts;
– communicating with Clients;

C) Purposes related to the interests of Traventuria LTD
– internal reporting;
– collection of receivables;
– conducting a check for complaints;

If Traventuria LTD needs to process information for purposes other than those listed above, Traventuria LTD will inform Clients to obtain their consent for this.

In case of non-provision of some or all of the personal data required during the reservation process, Traventuria LTD may be unable to provide a requested service, as a result of which it may refuse its performance.

3. Categories of Personal Data Recipients

For the purpose of fulfilling its objectives, Traventuria LTD discloses personal data of Clients to:

– suppliers who provide services on behalf of Traventuria LTD for the purpose of using the online system for selling bus tickets for passenger transport on regular lines of Traventuria LTD;
– independent agents or intermediaries for the purpose of using the online system for selling bus tickets for passenger transport on regular lines of Traventuria LTD;
– commercial partners for the purpose of using the online system for selling bus tickets for passenger transport on regular lines of Traventuria LTD;
– public or judicial authorities, upon request, in and to the extent permitted by law;
– other administrators on whose behalf Traventuria LTD processes personal data or who are joint administrators with Traventuria LTD;
– persons who perform services for the provision and maintenance of equipment, software, and hardware used for processing (including storage) of personal data, for payment reporting, etc.

4. Transfer of Personal Data Outside the European Economic Area (EEA)

Traventuria LTD may carry out international data transfers originating from the EEA when the European Commission has recognized a country outside the EEA as ensuring the appropriate level of data protection. For transfers to countries outside the EEA whose level of protection is not recognized by the European Commission, Traventuria LTD will rely either on a specific derogation applicable to the specific situation, in accordance with the Regulation (e.g., if the transfer is necessary for the performance of Traventuria LTD’s contract for passenger transport) or will apply one of the safeguards provided for by applicable legislation. In other cases for the transfer of personal data outside the EEA, this is done based on the explicit consent of the Clients for the proposed data transfer.

5. Period of Storage of Personal Data

Traventuria LTD retains personal data for Clients for the longer of the periods necessary either to comply with applicable laws and regulations, or another period according to the requirements applicable to Traventuria LTD’s activities. The processing of personal data is based on the principle of data minimization, depending on the purposes of providing the services used by the respective Client, and the use of Traventuria LTD’s online system for purchasing tickets. Part of the data may also be stored after the completion of the service requested by the Client for the purposes of providing discounts to regular clients, for fulfilling legal obligations of Traventuria LTD, or for the legitimate interests of the company.

6. Rights of Clients in Connection with Personal Data Protection and How to Exercise These Rights

The Client has the right to:

– information, when personal data is collected from him or from third parties;
– right of access to their personal data and more specifically: (i). confirmation whether personal data concerning him are processed by Traventuria LTD; (ii). providing access to the data through – a copy of the data that are being processed, as well as information about the purposes of processing; the categories of personal data; the recipients or categories of recipients to whom the personal data are or will be disclosed; the terms for storing personal data; the existence of the right to correction or deletion of personal data, or restriction of the processing of personal data, or to object to the processing; the right to complain to a Supervisory Authority (which in the Republic of Bulgaria is the CPDP); the sources of personal data; the existence of automated decision-making, including profiling;
– right to rectification – to require the correction or completion of his personal data if they are inaccurate or incomplete;
– right to erasure of personal data, when the grounds provided for in the applicable legislation exist;
– right to restriction of processing;
– right to data portability;
– right to object;
– his right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or similarly significantly affects him;
– giving, changing or withdrawing consent for the processing of personal data, when the basis for processing is his consent;

Clients can exercise their rights by submitting a written application to Traventuria LTD, in one of the following ways:

– personally, by a legal representative or through their representative authorized with a notarized power of attorney, at the office of Traventuria LTD, located at: Sofia, “Gorski patnik” Str. 54, after identification of the applicant or their respective representative by an employee of Traventuria LTD;
– by electronic mail to the data protection officer with a qualified electronic signature, in accordance with the Electronic Document and Electronic Certification Services Act;
– by mail by sending a notarized application, for the purpose of ensuring the identification of the applicant.

7. Amendments Regarding Data Protection

Traventuria LTD informs interested parties of any significant changes to these conditions through its website.

8. Contact with Traventuria LTD on Data Protection Matters

In case of questions related to the processing of personal data, in accordance with these General Terms and Conditions, Clients can contact the Data Protection Officer of Traventuria LTD at e-mail: info@traventuria.com.