Privacy Policy

HIP CAMPERS AD, UIC: 208024941, is a personal data controller, with its registered office and business address at: Sofia, postal code 1434, Vitosha District, 62 Shumako Street, apt. B1-10. You can contact the Company at the above address, as well as through the contact form on our website.

Data subjects have the following rights regarding the processing of their personal data:

• Right to lodge a complaint with the Commission for Personal Data Protection and/or the competent court – If you believe that we are unlawfully processing your personal data, you have the right to lodge a complaint with the Commission for Personal Data Protection, whose contact details are available on its website: https://www.cpdp.bg/; address: Sofia, postal code 1592, 2 Prof. Tsvetan Lazarov Blvd., email: kzld@cpdp.bg, and/or with the competent court. We kindly ask that you contact us first so that we may take immediate measures.
• Right of access – You have the right to obtain information from us as to whether personal data concerning you is being processed; you have the right to access the data and to receive information in connection with its processing.
• Right to rectification – You may request that we rectify inaccurate personal data concerning you, as well as provide additional data, including by completing a declaration for inaccurate or incomplete personal data.
• Right to erasure – You have the right to request the deletion of your data, and the right to have the respective data erased; the data may not be erased despite your request when there is a lawful basis for its processing, in which case each situation is reviewed individually and data subjects are informed of the decision taken.
• Right to restriction of processing – You may exercise this right in the following situations:
  a) when you contest the accuracy of the personal data, for a period enabling the Company to verify its accuracy;
  b) when the processing is unlawful but you do not want the personal data to be erased and instead request that its use be restricted;
  c) when the Company no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise, or defense of legal claims;
  d) when you have objected to the processing pending verification of whether the Company’s legitimate grounds override your interests.
• Right to object to processing – You have the right to object to the processing of personal data concerning you that is based on the Company’s legitimate interests.
• Right to data portability – You have the right to receive the data we hold about you, which you have provided to us, or to have it transmitted to another controller, where it is processed by automated means and on the basis of your consent or a contract.
• Right to withdraw consent – You have the right to withdraw your consent to the processing of personal data at any time (when the basis for processing is consent); the withdrawal of consent takes effect going forward and does not affect the lawfulness of processing based on consent before its withdrawal.
• Rights related to automated decision-making, including profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You may exercise your rights under the General Data Protection Regulation in any of the following ways:

• By submitting a written request to HIP CAMPERS electronically at the following email address: privacy@hipcampers.com; or
• By submitting a written request to HIP CAMPERS electronically via our contact form; or
• By submitting a written request to HIP CAMPERS in person or by post at the following address: Sofia, postal code 1434, Vitosha District, 62 Shumako Street, apt. B1-10.

In processing personal data, HIP CAMPERS applies appropriate and reliable technical and organizational measures to protect it.

Information about the processing of personal data by us in the various relationships in which we participate can be found in the following links.

The Company processes personal data of customers—users of goods, products, or services—or their representatives for the following purposes:

• Administering relationships related to the provision of goods, products, and services, including the conclusion and performance of contracts;
• Preparing individual offers for transactions;
• Issuing documents;
• Payments;
• Conducting risk assessments;
• Administering arising legal relationships;
• Providing assistance with claims and warranty services;
• Preventing fraud and/or other crimes;
• Complying with legal requirements;
• Exercising the Company’s legal rights—for example, to receive payments and perform contracts;
• Pursuing legitimate interests—for example, protecting the Company’s assets at its sites by implementing video surveillance for security purposes;
• Performing obligations under contracts with counterparties;
• Establishing contact when necessary;
• Reviewing complaints, grievances, and requests, applications and/or other submissions;
• Marketing and advertisement;
• Other lawful purposes.

For our customers and users of goods, products, and services, we may collect and process personal data as follows:

• Identification data – names, Personal Identification Number or other identification number, address(es), gender, nationality and/or citizenship, and other data, including from identity documents, if and when necessary;
• Contact details – administrative address(es), telephone number(s), email address(es);
• Bank details – IBAN;
• Information required for products, goods, and services, and in the event of certain occurrences – e.g., data regarding preferences related to the customization of products and goods, data on driving experience, insurance data, depending on necessity;
• Data from video surveillance at our premises;
• Data from the use of our website – in accordance with the information published therein.

The data may be collected directly from the customers/users or from other sources – public registers and third parties (representatives of customers/users, etc.).

We process personal data on the following grounds:

• Art. 6, para. 1, letter “b” of the General Data Protection Regulation – for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
• Art. 6, para. 1, letter “c” of the General Data Protection Regulation – for compliance with a legal obligation applicable to the Company;
• Art. 6, para. 1, letter “f” of the General Data Protection Regulation – in connection with the legitimate interests of the Company or a third party (for example, in the case of video surveillance, in connection with the performance of a contract with an insurer, counterparty, or other person, or the exercise of legal claims, marketing and advertisement);
• Art. 6, para. 1, letter “a” of the General Data Protection Regulation – with the consent of the data subjects, if and when applicable.

In processing personal data, the Company does not make decisions based solely on automated processing, including profiling.

The provision of personal data is voluntary; however, if such data is not provided, the Company may be unable to fulfill applicable requirements or contractual obligations. The customer/user will be informed in each specific case of the particular consequences of not providing the data.

The data is processed by employees of the Company who have undertaken obligations to maintain the confidentiality of information that has come to their knowledge in the performance of their official duties and who have received such information specifically in connection with the duties they perform within the Company.

The Company may disclose and provide personal data to the following categories of third parties: insurers, insurance intermediaries, banks, companies within its group, subcontractors acting as personal data processors, service providers (accounting, IT, and/or others), external consultants (lawyers, auditors, accountants, appraisers, experts, and other specialists), transport service providers and postal operators, competent state, administrative, and judicial authorities, as well as other natural and/or legal persons to whom it may assign the processing of collected personal data.

Data may be provided to such recipients in connection with the performance of our contractual obligations, as well as for the purpose of complying with legal obligations.

The Company does not intend to transfer personal data to third countries or international organizations. In the event of such a transfer, it will be carried out in compliance with the applicable legislation, ensuring the required level of protection.

If it becomes necessary for HIP CAMPERS to transfer personal data, including your personal data, to third countries (outside the European Economic Area – EEA), such transfer will always be conducted in full compliance with all requirements of Regulation (EU) 2016/679, including reliance on an adequate level of protection in the respective country as determined by the European Commission (EC) at the time of the transfer, or the application of other protective measures.

It is possible that, in the course of processing, applications or the services of data processors may be used to facilitate organizational processes, and such processors may be established in countries outside the EEA. In such cases, and in any event involving the provision of personal data outside the EEA, the requirements of the General Data Protection Regulation will be observed, and transparency for data subjects will be ensured.

The Company retains personal data for the following periods:

• No more than three (3) months for transactions that have not been finalized;
• Until the withdrawal of consent;
• No more than ten (10) years after the termination of the contractual relationships in connection with which the data was processed;
• After these periods – only when necessary (for example, for legal claims) or when there is a legal basis.

After the expiry of these periods, the data is deleted/destroyed in a secure manner.

HIP CAMPERS is a legal entity and an employer. In the course of its operations, in fulfilling its legal obligations, and for its needs, the Company primarily cooperates with other legal entities (companies providing services to HIP CAMPERS, banks and financial institutions, insurers, insurance intermediaries, suppliers, partners, etc., as well as companies within its group) which, in these relationships, are represented by natural persons whose personal data is processed.

The personal data of such individuals is processed for the following, non-exhaustively listed, purposes:

• In connection with the conclusion, performance, and termination of contracts; for the receipt of services, goods, and products; for contractual payments; and for contacts on operational and other matters;
• For the administration of contractual relationships;
• For the provision and receipt of services;
• For the improvement of processes related to the performance of contracts;
• For compliance with the Company’s legal obligations;
• For the provision of benefits to the Company’s employees;
• In connection with the application of measures against money laundering and terrorist financing, to the extent applicable;
• For the use of subcontractor services;
• For the exercise of claims, complaints, and similar actions.

The legal grounds for processing the data are compliance with legal obligations applicable to the Company (Art. 6, para. 1, letter “c” of the General Data Protection Regulation) and the legitimate interest of the controller (Art. 6, para. 1, letter “f” of the General Data Protection Regulation) related to carrying out its activities as a legal entity and employer, including for receiving services that support its operations. These grounds arise from the applicable legislation concerning the services and activities provided by HIP CAMPERS, the Obligations and Contracts Act, the Commercial Act, the Tax and Social Insurance Procedure Code, the Accountancy Act, the Measures Against Money Laundering Act, the Measures Against the Financing of Terrorism Act, the Electronic Communications Act, the Consumer Protection Act, and other laws and applicable secondary legislation.

HIP CAMPERS processes personal data of representatives of counterparties depending on the specific case and necessity. The data that may be processed include: names, Personal Identification Number (in certain specific cases under service contracts where counterparty employees provide specific services or where such data is indicated in powers of attorney), correspondence address, telephone number, email address, other contact details, place of employment, and employer information.

Information that such individuals share during communication with us (in meetings, exchange of letters and emails, telephone calls, chats, sending text messages, emails, and others), which may contain personal data, may be processed if it is related to the relationships between the parties.

The data will be obtained from our counterparties or directly from the individuals – data subjects. Where necessary, public sources may be used, such as the counterparty’s website, the Commercial Register and the Register of Non-Profit Legal Entities, and/or others.

If personal data is requested from the data subjects and they do not provide it voluntarily, other lawful means and methods may be used to obtain such data, including contacting counterparties. In each specific case, the individuals will be informed of the consequences of not providing the data.

The data is processed by employees of the Company who have undertaken obligations to preserve the confidentiality of information that has become known to them in the performance of their official duties and who have received such information specifically in connection with the duties they perform within the Company.

In compliance with applicable legislation and in the cases provided for by law, data may be disclosed to competent administrative and judicial authorities and institutions. Data may also be provided to personal data processors and their subcontractors (providing services necessary for the activities of HIP CAMPERS) with whom contracts have been concluded containing provisions ensuring the appropriate protection of personal data. Data may be provided to postal service operators in connection with such services, to banks, IT service providers, auditors, consultants, and others, with such disclosure to third parties being carried out following an assessment, in each specific case, of the necessity of the disclosure.

HIP CAMPERS will not provide personal data of representatives of its counterparties to countries or organizations outside the European Economic Area. It is possible that data may be processed outside the European Economic Area when using communication platforms, provided that the requirements of the General Data Protection Regulation are met and transparency is ensured.

If, in the future, the need arises for other transfers of personal data processed by the Company to third countries or international organizations, the provisions of the General Data Protection Regulation will be observed, including in the event of any subsequent onward transfer of personal data from the third country or international organization to another third country or organization.

Personal data of natural persons who are representatives of legal entities – counterparties – will be processed by HIP CAMPERS for no longer than is necessary to achieve the respective purpose for which the data was collected, or until the expiry of the statutory period (e.g., the periods under the Accountancy Act and others). After the expiry of these periods, the data will be deleted/destroyed in a secure manner.

HIP CAMPERS does not profile the representatives of its counterparties and does not make automated decisions that have legal consequences for these individuals.

HIP CAMPERS is an employer. In this regard, the Company processes personal data of applicants for employment with the Company.

In recruitment procedures, HIP CAMPERS receives the personal data of job applicants directly from them, via job application platforms, or through recruitment agencies if such services are used. In the second and third cases, before the data is received by HIP CAMPERS, it is processed by the respective platform/recruitment agency, without HIP CAMPERS being involved in such processing. It is also possible to process publicly available information from the applicant’s profile on the professional network LinkedIn and/or another professional network used for this purpose.

In the course of personnel selection, the following categories of personal data are processed: identification data, data on educational degree and additional qualifications obtained, data on acquired professional experience and work history, telephone number and email address for contact, data from skill and integrity tests conducted for certain job positions, and data exchanged during interviews.

The personal data of applicants is processed on the following grounds: Art. 6, para. 1, letter “b” of the General Data Protection Regulation – for taking steps at the request of the applicant prior to entering into a contract (the pre-contractual relationship between the applicant and the Company); Art. 6, para. 1, letter “f” of the General Data Protection Regulation – the legitimate interest of HIP CAMPERS to select employees who meet the requirements for the position applied for; Art. 6, para. 1, letter “c” of the General Data Protection Regulation – for compliance with legal obligations applicable to the Company, provided for in labour legislation, for example, the Labour Code; Art. 6, para. 1, letter “a” of the General Data Protection Regulation – consent, where applicable.

The processing is carried out for the following purposes: selecting suitable candidates for vacant positions at HIP CAMPERS, as well as for the preparation of employment documents for approved candidates.

In the first stage of the recruitment procedure, the Company processes the personal data of job applicants as provided in their curricula vitae (CVs), as well as, where applicable, any data in the applicant’s LinkedIn profile and in completed forms on the Company’s website submitted to HIP CAMPERS by the applicants. Data provided in cover letters, references, and/or other documents, if such have been submitted by the applicants, are also processed.

HIP CAMPERS has not established a specific CV (curriculum vitae) template and does not restrict applicants to using one. A CV may be submitted in a format chosen by the applicant, and it should contain information in accordance with the requirements announced by the Company for the vacant position. By using standard European CV formats, applicants may provide the following personal data: full name, address, contact details (telephone number, fax, email address), nationality, citizenship, date of birth, information on work experience, education, qualifications and training, as well as information on personal, social, organizational, technical, and other competencies. In accordance with the standard templates, a current photograph is attached to the CV. Applicants may also include other information in their CVs at their own discretion. The data contained in the CV submitted by the applicant will be processed in full during the review of the application.

When an application is submitted through the HIP CAMPERS platform on the Company’s website, where applicable, the data specified there will be processed.

The data contained in CVs sent by applicants or submitted online is processed by the Company’s employees performing recruitment functions, or by a data processor acting on behalf of and for the account of HIP CAMPERS, as well as by persons in managerial positions within the Company, such as the head of the department with the vacant position. Data about applicants may also be disclosed to public authorities where there is a legal basis for such disclosure.

After reviewing the received CVs, HIP CAMPERS contacts the candidates who have passed the first stage of the selection process and invites them to participate in the second stage – an interview. This second stage involves a discussion regarding the information provided in the first stage and aims to further assess the candidate’s potential ability to perform the duties of the position applied for, as well as compliance with the established requirements and criteria.

The interviews are conducted by a team of the Company’s employees who are competent to assess the candidate’s suitability for the position, as well as by the department in which the vacancy exists. For certain positions involving access to sensitive information relating to the Company and its clients, additional tests may be applied, such as those assessing specific knowledge and skills, professional orientation, integrity, and others, depending on the position in question. Interviews may be conducted either before or after such tests.

If job applicants do not provide HIP CAMPERS with information at any stage of the recruitment process that would allow an assessment of the suitability of their application, they may not be invited to participate in the next stage. It is also possible that applicants may formally meet the requirements but are not invited to proceed in the selection process because other applications are considered more suitable for the specific position.

After the completion of the second stage of the selection process, the Company contacts the relevant individuals to inform them whether they have been approved to start work at HIP CAMPERS. From the approved individuals, during the process of concluding the employment contract, additional data will be requested as necessary for the conclusion of the contract, in accordance with the requirements of labour and other applicable legislation, as well as the specifics of the position applied for.

The personal data of job applicants at HIP CAMPERS is not transferred to countries or legal entities outside the European Economic Area, nor to international organizations. If such a transfer takes place or such processing otherwise occurs (for example, the use of platforms that process data in third countries), the requirements of the General Data Protection Regulation will be observed and the necessary transparency will be ensured.

HIP CAMPERS does not carry out automated decision-making. It is possible that, at certain stages of the selection process, some profiling may be conducted based on information previously provided by the applicant; however, the decision regarding compliance with the employer’s requirements for occupying the vacant position is always made after a detailed analysis of all data and by humans, not by machines, taking into account all relevant factors.

The personal data of job applicants is retained by HIP CAMPERS for the following periods:

• For approved applicants with whom an employment contract is concluded – the necessary data is retained for the duration of the employment contract, and after this period – only where necessary (for example, for legal claims) or where there is a legal basis;
• For unsuccessful applicants – the data submitted during the application process is retained for a period of up to six (6) months from the completion of the recruitment procedure, unless the applicant has consented to its retention for a longer period.

After the expiry of these periods, the data is deleted/destroyed in a secure manner.

“Information when using the website” may include data about online activity which, in most cases, does not in itself identify a natural person (does not constitute personal data), such as browser type, operating system, most visited sections of the page and links on the website, entry and exit points, number of completed forms, time spent on the page, most popular keywords used outside the site that lead users to the website, information collected through cookies (depending on which cookies are enabled), and other device events, such as system activity.

In certain cases, personal data and information regarding the use of the website may be linked. Different types of usage data may also be combined, and once linked, they may lead to the identification of a specific individual. Furthermore, some usage data may be treated as personal data under applicable law.

HIP CAMPERS collects certain information that website users provide, as well as data from the use of the website and the services we offer through it. The information we collect and how it is processed depend on how the website is used and on the relevant permitted settings. Some data may be collected automatically through the use of cookies and other similar data collection tools, over which data subjects have control.

HIP CAMPERS applies special mechanisms that allow users of the site to manage cookies and other applicable technologies. The browsers used also provide such options.

HIP CAMPERS collects personal information and website usage data when a user submits a request for any of our services, contacts us, otherwise provides personal information, or uses other services. We also collect information and content that you send us when you enter data into the contact forms on our website, request additional information about a particular service, or engage in other types of communication with us.

Information We May Collect Through Automated Technologies

While you browse and use our website, we may use automated data collection technologies to process certain information about devices, searches, and trends, including:

• Details of visits to our website, including traffic data, location data, logs, and other communication data, as well as the resources that users access and use on the website;
• Information about the device and internet connection used, including IP address, operating system, and browser type.

We may also use technologies to collect information about online activities across third-party websites or other online services.

The information we collect automatically helps us improve our website and provide a better and more personalized service.

All information processed by HIP CAMPERS in connection with the use of its website is stored on secure servers.

The technologies for automated data collection may include:

Cookies (Browser Cookies)

A cookie is a small text file or packet of information stored on the hard drive of the end device (computer, mobile phone, tablet) when visiting a website. The website’s server can later retrieve or read the contents of the cookie. Cookies help users navigate websites efficiently and enable certain functionalities on these sites (for example, remembering user preferences such as language, settings, font, etc.).

Enabling all cookies is not strictly necessary for the website to function, but it may improve your browsing experience. You can change your cookie settings or refuse to accept cookies, other than strictly necessary ones, in your browser by activating the appropriate setting.

Cookies may include the following categories:

• Strictly necessary cookies – essential for the use of the website and for the provision of requested services. These cookies enable the website to function by supporting basic features such as page navigation and access to secure areas of the site. The website cannot function properly without these cookies, and therefore they cannot be disabled.
• Functionality cookies – allow the website to remember information that changes the way the website behaves or looks, such as the user’s preferred language or the region in which the user is located.
• Statistical cookies – help website owners understand how visitors interact with websites by collecting and reporting anonymous information.
• Marketing cookies – used to track visitors across different websites. Their purpose is to display ads that are relevant and engaging for the individual user, thus making them more valuable for third-party advertisers and publishers.
• Unclassified cookies – those that are in the process of being classified together with their providers.

Most web browsers allow cookies to be placed on the end device by default, but also provide options to control the cookies used through their respective settings.

More information about cookies can be found at www.aboutcookies.org or www.allaboutcookies.org. You can also use the cookie management options available in your browser (Google Chrome, Microsoft Edge, Mozilla Firefox, Opera, Apple Safari, etc.). Information can also be found on the websites of other parties that use cookie data, such as Google.

Web Beacons

Website pages and emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs), which may, for example, allow us to count users who have visited specific pages or opened an email, as well as for other website-related statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Other Technologies

To improve the functioning of the website, provide personalized services, measure the effectiveness of content and marketing, as well as for security and analytics purposes, this website may also use other technologies to collect information about user activity, such as pixel tags, local storage, device recognition technologies, and other similar solutions. Such technologies may collect information such as: browser type, operating system, IP address, devices used, duration of visit, on-site actions, traffic source, and other metadata.

The technological environment is developing dynamically, and other mechanisms with similar functionality may be used in the future. Whenever technologies that process personal data are used, the principles of transparency, lawfulness, data minimization, and the implementation of appropriate technical and organizational protection measures will be observed.

We do not automatically collect personal information through the above methods; however, where necessary and appropriate, such information may be linked to personal information from other sources, in compliance with legal requirements.

Use of Cookies and Other Tracking Technologies by Third Parties

The website may contain content or applications, including advertisements, that are served by third parties, including advertisers, advertising networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information. The information collected may be linked to personal data, or it may include personal and other information collected about online activities over time and across different websites and other online services. They may use this information to provide interest-based advertising or other targeted content.

We do not control the tracking technologies of these third parties or how they may be used. If you have any questions about an advertisement or other content directed at you, you should contact the responsible provider directly.

How Is the Information Used?

The information collected through the website is used to provide the relevant services, to improve and personalize the website and services, as well as to detect, prevent, and mitigate fraudulent or illegal activities, in accordance with applicable law. The information may be used to:

• Provide our services;
• Fulfill any other purpose for which it was provided;
• Operate our business, improve and personalize the services we offer;
• Perform customer service, security management, problem detection, creation of archives, and backups in connection with the provision of services;
• Communicate with users via email, telephone, or other means;
• Better understand how users access the website and services in order to improve them and respond to user preferences;
• Help us develop new services and improve existing ones;
• Enable users to receive advertising and direct marketing that is more relevant to them;
• Evaluate the effectiveness of, and improve, advertising and other marketing and promotional activities related to the services;
• For any other purposes with your consent.

Legal Grounds for Processing Personal Data

The data collected through our website may be processed on the following grounds:

• Consent (Art. 6, para. 1, letter “a” of the General Data Protection Regulation) – the data subject has given consent to the processing of their personal data for one or more specific purposes; this applies when no other legal ground exists, and for the consent to be valid, it must meet the requirements established by law;
• Contractual basis (Art. 6, para. 1, letter “b” of the General Data Protection Regulation) – the processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
• Compliance with a legal obligation applicable to the controller (Art. 6, para. 1, letter “c” of the General Data Protection Regulation);
• Legitimate interest (Art. 6, para. 1, letter “f” of the General Data Protection Regulation) – the processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child; the processing of data for advertising purposes and for the improvement of our services is based on the Company’s legitimate interest.

Disclosure and Sharing of Information

We may disclose and share personal information that we collect or that you provide to contractors, service providers, and other third parties we use to support our operations, who are contractually obliged to keep personal information confidential and to process it only for the purposes for which we disclose it, in order to achieve the purpose for which you provide the information or with your consent.Сигурност и мерки за защита на данните

HIP CAMPERS applies all appropriate physical, organizational, and technical security measures to protect your personal data from accidental loss, unauthorized access, use, and disclosure, including minimizing the volume of personal data processed to what is necessary to achieve the respective purposes, as well as restricting access to the data on a “need-to-know” basis; timely restoration of availability and access to personal data in the event of a physical or technical incident; continuous employee training and obtaining explicit confidentiality commitments from employees; and agreements with personal data processors.

This notice may be updated periodically and without prior notice to reflect changes in applicable legislation and in HIP CAMPERS’ Data Protection Policy. The Company undertakes to inform you in a timely and appropriate manner of any material changes to this notice.