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Privacy

Privacy

Definitions For the purposes of the present statement, the terms used in it are defined as follows:
  • personal data“ means any information relating 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 numbe (PIN, PNF or other), location data, an online identifier (such as IP) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • processing“ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destructionе;
  • controller“    means the 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;
  • consent“ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;All other terms used in the present statement have the meaning given to them in Article 4 of the Regulation.  
Context Leading the way in global assistance “Eurocross Assistance Bulgaria” EOOD (Eurocross) is part of “Astrum Assistance Alliance” – association of the leading assistance centres in Europe. The sole owner of its capital is Eurocross Assistance Netherlands B.V. /part of Achmea holding B.V./ –  a company that has been leading the way in global assistance since 1982. Millions of people can count on assistance from Eurocross, anywhere in the world. Medical and travel assistance, as well as closer to home, such as for damages caused by fire, storm, or water. Eurocross also offers security with Eurocross Personal Alarms, allowing older people or people with a physical disability to live independently for longer. This privacy policy governs the way in which Eurocross Assistance Bulgaria EOOD collects, uses, maintains and publishes data from its customers. This privacy policy is published on the website and applies to all products and services offered by Eurocross Assistance Bulgaria EOOD.   “Eurocross Assistance Bulgaria” EOOD is a data controller under the meaning of article 4, § 7 of Regulaton (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter reffered to as “the Regulation”, as it determines the purposes and means of the processing of personal data of natural persons. Details about the controller: UIC: 175309218 Seat and address of management: office 2, 2nd fl., 45 Bulgaria bld., Triaditsa distr., Sofia 1404 Contact persons with regard to questions concerning processing and protection of personal data: Elena Ilieva and Polina Todorova E-mail: info@eurocross.bg Telephone: + 359 2 804 3 800 Fax: + 359 2 979 4 691 “Eurocross Assistance Bulgaria” EOOD processes personal data of the following categories of natural persons: Insured persons (clients); Employees; Contractors; Natural persons addressing to Eurocross applications and other documents; Achmea B.V. is responsible Eurocross Assistance is an Achmea brand. Achmea B.V. is responsible for the proper processing of your personal data for all Achmea brands. Your data in reliable hands Are you requesting assistance from Eurocross Assistance? Then we need certain information. It is important to us that you know what we do with your personal data and what rights you have. We want you to be confident that your data is in good hands with us. What personal data do we process? Clients We process the following client data:
  • Identification data: Name, address, date of birth, gender, e-mail address, place of residence and other similar data required for communication;
  • Data concerning Family composition and the names of the partner and any children;
  • Social identity: Nationality;
  • Internal numbers used by Achmea to identify you, such as the client or policy number and other insurance information;
  • Health data;
  • Data on the incident for which assistance is requested:
    • reason of the request for assistance
    • nature or extent of the damage
    • location, date or time of the incident
    • client’s current location and duration of stay
    • other data required for providing assistance
  • Number plate;
  • The lease company, if it concerns a lease car.
The client’s relations With relations we mean family members, but also assistance providers. We process the following data of relations:
  • Identification data: Name, address, place of residence and other similar data required for communication.
  • Internal numbers used by Achmea to identify you, such as client number, policy number and other insurance information.
  • Data on the assistance provider, such as information from the BIG register.
  • Data on the incident for which assistance is requested.
What do we use your data for? We process personal data. We do so for multiple reasons:
  • To support Eurocross employees in their activities to provide adequate and efficient services
  • For carrying out assistance according to insurance terms and conditions. This concerns Eurocross Assistance’s customers’ insurance terms and conditions.
  • For the registration and management of data resulting from the execution of the assistance
  • To be able to process cases correctly financially.
  • In order to process your inquiries, requests, applications, etc. and provide you with a reply;
 Who will receive the data? People who will receive your data may include:
  • Eurocross customers, such as insurance and lease companies
  • Subsidiaries
  • Parts of Achmea B.V.
  • Departments within Achmea B.V., such as the board of directors, Legal, Risk & Compliance, Business Control, Internal Audit and Contract Managers
  • Assistance providers deployed directly or indirectly by Eurocross Assistance Bulgaria EOOD, such as roadside assistance.
  • competent public authorities when “Eurocross Assistance Bulgaria” EOOD shall comply with statutory obligations;
Is the recipient outside the EU? Eurocross Assistance Bulgaria EOOD operates worldwide. The location where a client or one of their travel companions falls ill or requires assistance is not known in advance. This is why we cannot have contracts—e.g. processing contracts or confidentiality agreements—with parties who offer assistance on location. As a result, we cannot always establish whether the protection of personal data is sufficiently guaranteed with these parties. In such cases, data will only be exchanged if the conditions set out in Article 49 of the GDPR are met. The GDPR states that the exchange of personal data is permitted if:
  • It is necessary to execute a contractual obligation;
  • It is in the interest of the person involved – in order to protect the vital interests of the data subject or of another natural person;
  • It is done at the request of and with permission from the person involved.
Why are we permitted to use personal data? The data we use and the reasons for which we use it depends on the applicable situation. We are permitted to use the personal data if at least one of the following situations, as laid down by law, applies:
  • We have permission to use the data. In that case, we have explicitly asked you for permission.
  • The use of the data is necessary for the execution of an agreement. This may be an agreement between you and us or between you and an insurance company.
  • The use of the data is necessary to protect vital interests. For example, if you have had an accident abroad and you are unable to speak to us yourself.
  • The use of the data is necessary for the representation of our or a third party’s interests (unless your interests are more important). These must be justified interests, such as:
      • Administrative reasons
      • IT goals
      • Marketing
      • Fraud prevention
      • Management information
      • Product and service development
What moments of contact do we record? We record what we have agreed with you and all the correspondence with you. We use our moments of contact to improve our communication as well as when we need it in order to perform our contract obligations. Examples of moments of contact we record are:
  • Letters and emails we send and receive from you
  • Phone calls
How do we ensure your data is safe with us? Our websites, apps and IT systems are well-protected. We continually take extra measures to prevent the misuse of your data. Our employees have received clear instruction on how to handle your data lawfully and in respect of the principles set in the GDPR. We are extra careful with sensitive data Sensitive data includes your Social Security number, bank details and medical details (which the Regulations qualifies as “special categories of personal data”). Our medical consultants are responsible for correctly processing your medical data. These medical consultants are BIG-registered doctors or nurses. Employees only have access to your medical data if they have permission from a medical consultant. Both the medical consultants and the employees have a confidentiality obligation.   How long do we store your data? We store your data for as long as is necessary to achieve the purposes indicated in the present Statement in accordance with the statutory deadlines for the relevant documentation. We store telephone conversations for a period of 2 years.   We also use cookies Eurocross Assistance Bulgaria EOOD uses cookies that are of little influence to your privacy. These cookies are called analytical cookies. We use them to collect statistics about the use of our website to improve it and make it more user-friendly. We also use these cookies to save data such as:
  • Technical characteristics, such as which browser you use
  • What device you are using
  • From which website you linked to ours
  • When you visited and how long you spent on our website
  • Which pages you visited on our website
This data cannot be traced back to a person. We always place these cookies. We do not ask for your permission for this. Cookie-overview See the overview of cookies we use and the parties involved.
Cookie supplier Type of cookie Reason(s) for cookie Stored personal data Period of validity of cookie
Matomo (Piwik) Analytical Insight into the use of the website None 13 months
Privacy laws and regulations. We comply with privacy laws and regulations.
  • The General Data Protection Regulation;
  • Law on personal data protection;
  • All other legal acts that related to the processing and protection of the personal data we process;
Your rights You have the rights described below. The exercise of these rights is free of charge, except in the case of repeated or excessive requests. In this case, “Eurocross Assistance Bulgaria” EOOD may require payment of a certain fee for additional administrative expenses. 1.) Right of access by the data subject You have the right to obtain from “Eurocross Assistance Bulgaria” EOOD confirmation as to whether or not personal data concerning you are being processed. Where that is the case, we will provide you with access to the personal data and the following information:
  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
  • the envisaged period for which the personal data will be stored, or the criteria used to determine that period;
  • the existence of the right to request from “Eurocross Assistance Bulgaria” EOOD rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  • the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
If you explicitly specify such a request in your application, we will provide you with a copy of the personal data that is being processed. Please note that you will be subject to a reasonable fee due to the administrative costs incurred when you request additional copies. 2.) Right to rectification You dispose of the right to obtain from “Eurocross Assistance Bulgaria” EOOD without undue delay the rectification of inaccurate personal data concerning you. In the event that the personal data concerning you is incomplete, you can request its completion, including by means of providing a supplementary statement.
  1. ) Right to erasure (‘right to be forgotten’)
You dispose of the right to request the erasure of the personal data concerning you where one of the following grounds applies:
  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you have withdrawn consent on which the processing is based and where there is no other legal ground for the processing;
  • you object to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for the purposes of direct marketing;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  • the personal data have been collected in relation to the offer of information society services;
  1. ) Right to restriction of processing
You have the right to request the restriction of the processing of personal data concerning you, i.e. tagging relevant personal data to restrict future processing, in the following cases:
  • you contest the accuracy of the personal data and the restrictions is for a period enabling “Eurocross Assistance Bulgaria” EOOD to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • “Eurocross Assistance Bulgaria” EOOD no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims;
  • you have objected to processing pending the verification whether our legitimate grounds of override those of your interests;
The limitation methods we use are a temporary move of the selected personal data to another system for processing and / or terminating users’/processors’ access to them. In the event that we have corrected or deleted personal data relating to you or have limited their processing, we will inform each recipient to whom they have been disclosed, unless this is impracticable or requires disproportionate effort. If you request that, we will provide you with information about who these recipients are. 5.) Right to data portability You have the right to receive the personal data concerning you, which you have provided in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or on a contract and shall be carried out by automated means. . In order to be able to implement your request for direct transfer of personal data to another controller, this controller shall also have technical means to receive your personal data. 6.) Right to object You have the right to object at any time to processing of personal data concerning you which is based on the legitimate interest of “Eurocross Assistance Bulgaria” EOOD. “Eurocross Assistance Bulgaria” EOOD will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Do you want to use the above-mentioned rights? In this case, you can file a written application (hyperlink for download) to the addresses listed below. The application should specify which of the mentioned above rights you wish to be satisfied with a description of the request and the preferred actions for its implementation. In the application, you should indicate your full name, PIN, permanent address, address for correspondence, other identification data and also preferred form of communication. Once you specify the date and sing the application, you have the following options to provide it to us:
  • via e-mail in accordance with the The law on the electronic signature and the electronic certification services or the Law on e-Governance;
  • personally at the following address: office № 2, 2nd fl., 45 Bulgaria bld., Triaditsa distr., Sofia 1404.The application may be filed personally by you and by another person with a notary certified power of attorney.
  • Via post or courier with a return receipt to the following address: office № 2, 2nd fl., 45 Bulgaria bld., Triaditsa distr., Sofia 1404
In this case, the signature on the application should be certified by a notary in order for us to be able to identify your identity in an indisputable manner. In the event that we are unable to identify your identity indisputably, we reserve the right to request the provision of additional information. If you have any questions, tips or complaints concerning privacy, In the cases described above, please send an email to Еurocross’ Data Protection Officer Luc Donkhorst via Luc.donkhorst@eurocross.nl.This person is responsible for all questions concerning the processing and protection of personal data for the whole group of undertakings. You can also send a letter to: P.O. box 175, 2300 AD Leiden Data protection officer details: Luc Donkhorst Manager Risk Compliance Eurocross Assistance Tel: +31 651539738 P.O. box 175 2300 AD Leiden You may also contact the persons responsible for the processing and protection of personal data in “Eurocross Assistance Bulgaria” EOOD, whose contacts are listed at the beginning of this statement. You also have the right to file a complaint before the Commission for personal data protection (CPDP): Address: 2 Prof. Tsvetan Lazarov bld., Sofia 1592 E-mail: kzld@cpdp.bg Website: www.cpdp.bg In addition to filing a complaint before the CPDP, you are entitled to:
  • file a complaint before the administrative court competent within the territory of the headquarters of Eurocross Assistance Bulgaria EOOD.
You have no right to bring the matter to court if there is a pending case before the Commission for the same violation or a decision on the same violation is appealed and there is no court decision in force;
  • claim compensation for material and non-pecuniary damage suffered as a result of violating your data protection rights – in cases where you believe we have breached your data protection rights guaranteed by the Regulation or other applicable statutory instrument and you have filed an appeal to the competent court. In the same proceedings, you have the right to claim compensation for the damages suffered by the respective violation of your rights.
We may change this Privacy Policy for example if anything changes in the laws or regulations or if we develop new products or services. The most up-to-date version is always published on our website. This version is dated 20 August 2018.