PRIVACY STATEMENT OF

Best Drive Ltd

Date of update: 08 June 2023

This document contains the Personal Data Protection Policy of “Best Drive” EOOD (“Avto Abo”), entered in the Commercial Register at the Registration Agency with EIC: 204280605, with headquarters and management address Sofia 1113, Izgrev district, “Tintyava” St. No. 15-17 with subject of activity: commercial activity, rental of motor vehicles and all other activities related to the provision of motor vehicles for rent (“Policy”) and is an integral part of the General conditions for providing services (“General Terms and Conditions – Auto Subscriptions (avtoabo.bg)”). If the Policy changes, the changes will be posted here.

In order to provide motor vehicle rental services (“Services”) on the website www. avtoabo.bg (“Site”), Avto Abo processes personal data of individuals – customers of Avto Abo or representing customers of Avto Abo (“Data Subjects”/”You”/”You”), in accordance with this Policy.

When processing personal data, Auto Abo complies with all applicable regulations on the protection of personal data, including, but not limited to, Regulation (EU) 2016/679 (“Regulation”).

Definitions:

– personal data is any information that relates to you and through which you can be identified, directly or indirectly;

– processing of personal data (“Processing”) is any action or set of actions that may be performed with respect to personal data by automatic or other means.

1. Purposes of Personal Data Processing

Auto Abo collects the data provided by you in connection with the provision of an offer and the conditions for concluding a contract for the use of Auto Abo’s services, the documentation of the actions on Processing of personal data and the fulfillment of the legal obligations of Auto Abo and the protection of the legitimate interests of Auto Abo according to the applicable legislation:

1.1. Conclusion and execution of a contract. These are the purposes necessary for the steps in the conclusion and execution of the contract between you and Auto Abo, including the data processing necessary for this when registering, creating an account and the activities of providing the Services available through the Site. In addition, these purposes include communicating with you, including by email, as necessary in connection with providing the Services and/or notifying you of changes to the Services provided. For this purpose, it may be necessary to process some or all of the above categories of data.

1.2. Legitimate interest. Auto Abo aims to ensure the normal functioning and use of the Site by you and other users, maintenance and administration of the Services, resolution of disputes, detection and prevention of malicious actions, including:

• Communicating with you electronically on important matters related to the Services;

• Receiving and processing received signals, complaints, requests and other correspondence;

• Implementation and protection of the rights and legal interests of Auto Abo, including by court order, and providing assistance in the implementation and protection of the rights and legal interests of other users of the site and/or affected third parties.

1.3. Legal obligations. These are obligations related to:

• Financial and accounting activities, in which it is necessary to process and store information required by law in order to fulfill tax, accounting and other reporting obligations;

• Activities to fulfill the obligations provided for in the law to preserve or provide information;

• Activities for the fulfillment of documentation obligations, reporting obligations and other obligations related to the fulfillment of the requirements of Regulation (EU) 2016/679 and the current legislation, including in connection with the obligations assigned by the Agreement for the processing of personal data and other applicable obligations.

1.4. Express consent. Your data may be processed on the basis of your express consent, and the processing in this case is specific and to the extent and scope provided for in the relevant consent.

Auto Abo processes personal data only in accordance with this Policy and to the extent permitted by law. Information is collected when you register on the website, subscribe to our material, provide answers, queries or comments, or fill out certain data in a form.

2. Personal data collected, stored and processed by Auto Abo. Storage period

Personal data	Aim	Storage period
Name	Receive an offer for Auto Abo Services	Up to 6 months from the date of sending the request for an offer
Adress, telephone, Email	Receive an offer for Auto Abo Services	Up to 6 months from the date of sending the request for an offer
Other data provided by you voluntarily	Receive an offer for Auto Abo Services	Up to 6 months from the date of sending the request for an offer
Logs for the use of the site	Receive an offer for Auto Abo Services	Up to 6 months from the date of sending the request for an offer

The use of the Site is possible without the need for registration and provision of any data by each user.

The personal data provided by you will be processed for the purposes of providing a service offer, as well as for the purposes of personalizing the web page in relation to your needs, improving the web page. Auto Abo may provide part of the received data to other third parties in connection with the fulfillment of your requests, requests and orders.

The services provided on this website are intended for persons over 18 years of age.

  3. Rights in relation to personal data

As a natural person, data subject, you have the following rights:

3.1. Right to information.

This Policy aims to inform you in detail about the processing of your personal data in connection with the Services provided.

3.2. Right of access.

You have the right to receive confirmation as to whether your personal data is being processed, access to it and information about its processing and your rights in this regard.

3.3. Right to rectification.

You have the right to correct your personal data if it is incomplete or inaccurate.

Your data can be corrected by you and/or your authorized representative.

3.4. Right to erasure.

You have the right to request deletion of data, except in cases where there is a substantial reason and/or legal obligation for their processing.

3.5. Right to restriction in relation to data processing.

The regulation provides for the possibility to limit the processing of your personal data if there are grounds for this provided for in it.

3.6. Right to notify third parties.

  If applicable, you have the right to ask Auto Abo to notify third parties to whom it has provided your data regarding the correction, deletion or restriction of the processing of your personal data.

3.7. Right to data portability.

You have the right to receive the personal data you have provided that relates to you in a structured, machine-readable format, and to use this data for another controller at your discretion.

3.8. Right not to be subject to a decision based solely on automated processing, including profiling, which gives rise to legal consequences for you or in a similar way affects you to a significant extent, unless there are grounds for this provided for in the applicable legislation on personal data protection and appropriate guarantees are provided for the protection of your rights, freedoms and legitimate interests.

Technologies falling into this category are not used when providing the Services on the Site.

3.9. Right to withdraw consent.

You have the right, at any time, to withdraw your consent to the processing of personal data based on your consent. Such withdrawal does not affect the lawfulness of the processing based on the consent given until the time of its withdrawal.

Data provided on the legal basis of consent are: the data for receiving marketing information.

3.10. Right to object.

You have the right to object to data processed on the basis of legitimate interest.

In the event of such an objection, We will consider Your request and, if justified, We will comply with it. If we believe that there are compelling legal grounds for the processing or that it is necessary for the establishment, exercise or defense of legal claims, we will inform you of this.

3.11. Right of appeal to a supervisory authority.

You have the right to file a complaint with a supervisory authority if you believe that the processing of personal data concerning you violates the applicable legislation on the protection of personal data. The supervisory authority in the Republic of Bulgaria is the Commission for the Protection of Personal Data, with address: Sofia 1592, “Prof. Tsvetan Lazarov” No. 2.

4. Person responsible for personal data protection.

If you have any questions regarding this Policy, please contact the Personal Data Protection Officer:

e-mail: info@avtoabo.bg

phone: 00359 886 777 024

address: 15-17 Tintyava Street, 1113 Sofia

5. NON-DISCLOSURE OF PERSONAL DATA

Auto Abo collects personal data only in accordance with the legislation in relation to the protection of personal data. Except in the cases provided for in this Policy, personal data will not be provided to other third parties. When it is necessary to provide your personal data to contractors of Auto Abo in connection with services provided by Auto Abo and its contractors, these data will be processed only in accordance with the requirements of the law and in connection with the requested services.

It is possible that certain personal data will be disclosed to competent authorities by virtue of a law, court decision or other appropriate act, and/or if their disclosure is necessary for the detection of crimes in the country and/or abroad.

6. LIABILITY

Auto Abo is not responsible for the personal data processing policies of web pages to which this web page contains links.

7. CONFIDENTIALITY

When processing personal data, Auto Abo takes all necessary measures to protect the information from loss, misuse, disclosure, modification or destruction, as well as publication to unauthorized third parties.