Terms of providing personal data



Basic Terms of Handling and Protecting Your Data (Privacy Policy)


"SNAD GROUP" LTD, VAT 206230832, with headquarters and address of management: Gr. Sofia, PK: 1330, bul. Rishki prohod, bl. 6, et.2, ap. 22 is a company registered in Bulgaria which, through platform HERAPLATFORM / ARENATA.com, is the administrator of personal data according to Regulation EU 2016/679 of the European Parliament and of the Council from 27 April 2016 on the protection of personal persons with regard to the processing of personal data and on the free movement of such data.

SNAD GROUP invests all the necessary resources and applies the strictest measures to protect the security and integrity of all personal data collected by our clients. We follow the principles of legitimacy, awareness, and transparency when we process our clients’ personal data.

Therefore, we collect and process the data provided only in view of specific, explicit and legitimate purposes and do not process further in a manner inconsistent with these purposes.

We have implemented systems and processes to ensure that the data we collect and store is minimized and related and limited to what is necessary to meet the goals we have collected. We try to ensure that your personal data is always accurate and up-to-date and we also rely on you if you find any inaccuracies in your data in order to resolve it in time.

We assure you that we have implemented systems to ensure that we do not store your data for a longer period than is necessary for the purposes for which it is being processed.

We also pay attention to the possibility at any time, without the need to justify, to withdraw your consent to process your data and to delete it if you wish, unless there are other legitimate reasons to protect it. Since it is a priority for us to process your data in a way that ensures the appropriate level of personal data security, including protection against unauthorized or unlawful processing or accidental loss, destruction or corruption, we have deployed security mechanisms and limited access.



Personal data is any information related to an identifiable natural person or an individual. Personal information includes your name, personal ID, email address, telephone, postal address, and more.

Processing means any operation or set of operations performed with personal data or a set of personal data by automatic or other means of collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, distribution or another way in which data become available, arranging or combining, limitation, deletion or destruction.


We collect your data on a voluntary basis when you provide it to us in view of your stated desire to sign a contract for the services we provide. After the conclusion of the Agreement, your data will be processed in your capacity as a party to this Agreement and in connection with the performance of our obligations under this Agreement. The provision of these data allows us to identify the individual as a party to the contract and as the holder of the rights/obligations under it. The full name, single citizenship number, and address of the person are part of the minimum content of each contract. If a person refuses to provide them, "SNAD GROUP" will not be able to sign a contract. In order to be able to perform the contracts, we have to process the personal data of the persons with whom we have concluded them. Otherwise, it will be impossible to comply with our contractual commitments.

- We process personal data when it is necessary to exercise our rights on contracts, as well as when it is necessary for the settlement of legal disputes.


- We process personal data when we are obliged to provide information to competent authorities.

- We process personal data in order to fulfill obligations stemming from accounting and tax legislation - in the Republic of Bulgaria, it requires a certain accounting and commercial information to be indited, including such information to be kept for a specified period, and any other information and documents relevant to taxation. In the performance of this obligation, the relevant information and documents containing personal data shall be kept for the periods provided for the laws.

  • SNAD GROUP does not share, sell, assign, trade or transfer personal information gathered by its clients.
  • By way of exception and in the presence of a legitimate reason, your personal data may be revealed to third persons in the following manner:
  • Can be transferred as an asset in connection with a merger or sale of business either as part of our business or as part of a corporate reorganization or other changes in corporate governance.
  • Service providers are not allowed to retain for their own use or use the data beyond our instructions. They do not have to keep them for longer than it is necessary to perform that service.
  • If the data transmission is needed, ”SNAD GROUP” obliges third persons, clients, employees and partners to maintain the confidentiality of the information and to confirm that your personal data are used only for the agreed purposes and will never be used to identify you as a person, contact you, or send you messages except for the purposes which they were provided. Third parties or partners will be allowed to receive only the information they need to perform their functions on our behalf. In addition, they must process personal data in compliance with the privacy policy of "SNAD GROUP", as well as the applicable data protection laws.
  • In connection with the above, we inform you that your data will not be transferred/ or processed and shared outside of the EU.
  • Your personal data may only be made available to governmental authorities when it is provided by the law and under the conditions set out therein.


  • We will keep your personal data for as long as is necessary to perform the goals and proof their execution in accordance with your instructions and your wish to withdraw your consent to process your data and delete it.


1. Information rights

You have the right to request information at any time:

  •  whether your personal data are stored;
  •  the purposes for which they are being processed,
  •  which categories of personal data are being processed;
  •  the recipients to whom your  personal data are revealed,
  •  provided term for which they will be stored;
  •  is there automated decision making and data profiling?


2. Withdrawal right

  •  If you have agreed to use your data, you may withdraw it at any time without the need to state the reasons.

3. Correction right

  • If you find that your data is inaccurately stored by us, you can contact us to correct them.

4. Right to delete your data

  • You may request to delete your data without unnecessary delay. We will erase them within a reasonable time as soon as we are satisfied that there are no other grounds for their processing/storage.
  • After deleting your personal information, it is no longer possible to provide information about them on our behalf.

5. Right to restrict the processing

  • In certain cases - for example, in case you contest the accuracy of the data when checking the grounds for their storage, etc., you have the right to request us to limit the processing of your personal data. During the limitation, we can only store the personal data and the other processing activities are only possible with your consent.


6. Data portability

In case of a request from you, we will transmit or transfer the data to you or another administrator in a structured, widely used and machine-readable format. Direct data transfer is only made if it is technically possible.

7. Right of objection

You may, at any time and without giving any reason to object to the processing of your personal data for the purposes of direct marketing, including profiling, and in cases where your data is processed for the performance of a public interest task or the processing is necessary for the purposes of our legitimate interests.

8. Right not to be the subject of a decision based solely on automated data processing, including profiling.

Currently “SNAD GROUP” does not perform automated data processing. Including profiling.

9. Right to complaint

You have the right to complain against the processing of your personal data in the Personal Data Protection Commission or the Court if you believe your data protection rights have been violated.

Personal Data Protection Commission:

Sofia, postcode 1592, "Prof. Tsvetan Lazarov” Str. № 2

Center for Information and Contacts - tel .: 02/91 53 318

E-mail: [email protected]

Website: www.cpdp.bg

Your request to use your rights regarding the personal data provided or the withdrawal of your consent can be sent to us by email: [email protected]

Please note that when you contact us via email [email protected], the information you provide (your email, your name, and your phone number) is handled by us in order to answer your questions and resolve the requested issue. We are committed to deleting the retained data in this regard once processing is no longer required or will limit the processing if there are legal obligations to store.

Present texts are written in Bulgarian and English, in case of contradiction in the text, the Bulgarian version prevails.

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