POLICY CONFIDENTIALITY AND PROTECTION OF PERSONAL DATA "HOT BEL-BG" EOOD
"Hot Bel-BG" Ltd. protects the personal data of its clients and partners, striving to maintain a good policy ensuring the maximum protection of your personal data processed during and / or in connection with the provision of basic and / or additional tourist services, and other services provided on-site at the Classic Family Hotel in Varna. This Privacy Policy is based on the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on cancellation of Directive 95/46 / EC ('Regulation (EU) 2016/679'). All changes and additions to the Privacy Policy will apply after the release of the up-to-date content available through our website: http://hotel-classic-varna.com. The privacy policy applies to your personal information if you are a natural person or a legal entity that uses or wishes to use the services provided at the Classic Family Hotel, including those offered online through a dedicated platform on our website, including and through social networks.
1.Who processes and is responsible for your personal data: HOT BEL-BG EOOD is the commercial company registered in the Commercial Register of the Registry Agency with UIC 202583404, which collects, processes and stores your personal data under the terms of this Policy and the applicable legislation of the European Union and the Republic of Bulgaria. HOT BEL-BG EOOD is a personal data controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of data. such data and the Personal Data Protection Act. For any questions regarding the processing of your personal information, you can contact us at our management address:
Varna city 9010 Seaside Park, 2535B Saltanat Avenue / Hotel Classic / or at the following contact information: http://hotel-classic-varna.com and email: hotel@hotel-classic-varna.com;
2. What data, for what purposes and on what legal basis do we process:
2.1 Depending on the specific goals and reasons, HOT BEL-BG EOOD processes the following data individually or in combination with each other:
a) The information you provide necessary to identify and execute your reservations and confirmed reservations, such as:
three names, telephone and / or e-mail address to contact you, or contact person, date of arrival and departure, children and their age;
- data collected upon payment made to us - credit or debit card number, bank account and other information collected at and processed in connection with making the payment by bank transfer, through direct debit or through the Post terminal of "HOT BEL -BG EOOD;
- your account information - username, email address, booking history and payments;
- other information you provide to us in relation to the services you already use or your preferences.
b) Data provided by you and stored by HOT BEL-BG EOOD in the process of providing and accommodation services at a family hotel Classic, which data are collected, processed and stored in accordance with the current regulatory requirements for keeping register of accommodated tourists by persons performing hotel business, namely:
- three names;
- EGN / for Bulgarian citizens / or LFN / for foreign citizens with a residence permit in BG /;
- date of birth;
- gender;
- citizenship;
- Identity card number / valid national identity document, country issuing the national document, Data collected for the purposes of hotel registration are collected on the grounds of Art. 116, para 1 and para 2 of the Law on Tourism and are necessary for keeping a Register for accommodated tourists.
c) Other: - Digital data - videos. This is the data collected through the video surveillance systems used by HOT BEL-BG EOOD in public places in the Classic Hotel (reception, corridor, staircase, entrance, terrace, garden, underground garage), with the purpose of monitoring and control.
- Data in connection with the claim filed regarding the tourist service provided by us and used by you;
- Information about the type and content of the reservation, as well as any other information related to it, including e-mail, letters, requests, requests, complaints, complaints and other feedback we receive from you;
2.2 Purposes and Legal Grounds for the Processing of Personal Data:
a) We process and store personal data that is the minimum necessary to provide a tourist accommodation service, as well as all other services provided on site, for the following purposes:
- Identification of a client when: making, modifying and canceling a reservation, as well as providing tourist accommodation services, as well as all other services provided on-site at the Classic Hotel. The identification of a customer is done through all commercial and communication channels - at the reception at the hotel by providing an identity document, by phone, on our online platform through an electronic contact form, by e-mail, etc .;
- Updating your personal data or information about services in our Hotels upon your request for correction / modification of data / services;
- Handling and responding to customer complaints / inquiries / complaints. Adjustments to amounts due on reservations already made, if there are grounds for this;
b) In fulfillment of its legal obligations, HOT BEL-BG EOOD processes your data for the following purposes:
- Provision of information to the Ministri of Tourizm sistem ESTI from 01.10.2019 , NSI, Ministry of Interior, Varna Municipality, Migration Department at the Ministry of Interior of Varna, Consumer Protection Commission, Personal Data Protection Commission and others in connection with the fulfillment of our obligations as a hotelier, arising from the current regulatory acts in this area;
- Processing your data in invoices issued to you for other purposes consistent with the original purpose for collecting them;
- Carrying out tax and social security control by the relevant competent state bodies;
- Collection of receivables from clients in court;
- Providing information to the court and third parties in court proceedings in order to protect their legitimate interests;
3. Categories of third parties who access and process your personal data: In connection with the conduct of our business and the fulfillment of our contractual obligations with our clients, we provide your data to the following groups of 'recipients', namely:
- to the data subject whenever they exercise this right;
- the users / customers to whom the data relate;
- to business partners - for the purposes of fulfilling your reservations - travel agents and agents in Bulgaria and abroad, transport companies and airlines, suppliers of the relevant basic and additional tourist services, and other subcontractors with whom we have contracts.
- IT companies supporting information systems, our company website, video surveillance, software and platforms for managing our customers' reservations, etc .;
- to public authorities (Ministry of Interior, Varna Municipality, NRA, Consumer Protection Commission, Personal Data Protection Commission, judicial and other control bodies);
- Other administrators and processors of data to which HOT BEL-BG EOOD provides your personal data on a legitimate basis and / or on the basis of a bilaterally signed contract.
4. How long your personal data is stored. Security:
The length of time your personal data is stored depends on the processing purposes for which it was collected: Your personal data processed for the purpose of providing and performing tourist accommodation services are stored for up to 3 (three) years from the date of your departure the hotel, and until the final settlement of all financial relations between the parties, subject to the statutory time limits, if any; Personal data or company data processed for the purpose of issuing accounting / financial documents for exercising the tax and social security control, but not only - invoices, debits, credit notices, shall be kept for at least 5 (five) years from January 1 of the reporting period. , subsequent to the reporting period to which they relate, unless the applicable legislation provides for a longer period. Picture (Video) - up to 30 days after recording. The storage of personal data for a longer period is possible for the protection of the legitimate interests of HOT BEL-BG EOOD, as well as for the expiry of the relevant limitation period in order to protect in case of any claims of clients in connection with the execution / termination of the tourist services provided. services at the Classic Hotel, as well as for a longer period of time in the event of a legal dispute - the documents are kept until its final decision by a court / arbitration decision. As a Personal Data Administrator, HOT BEL-BG EOOD takes due care and takes the appropriate administrative, technical and physical measures, as well as those related to the staff / training, information, etc. /, in order to protect the information, at its disposal, including the protection of the client's personal data from loss, theft and unauthorized use, disclosure, modification and any other illegal forms of processing. It has physical, electronic and procedural safeguards that comply with our legal obligations regarding the protection of personal data. HOT BEL-BG EOOD is responsible for the protection of the personal data of the clients / consumers who have become aware of it in connection with the performance of their business and the offered tourist services, specified in the subject of the General Terms and Conditions of this Policy, except in cases of force majeure, incidental or malicious acts of third parties, as well as in cases where the client has made this information available to third parties.
5. What are your rights in relation to the processing of your personal data by HOT BEL-BG EOOD and what actions should you take to exercise them:
- right of access to the data relating to it - the customer has the right at any time to ask us for confirmation that the data relating to him are processed, information for the purposes of this processing, data categories and recipients or categories of recipients to which the data is disclosed;
- the right to correct and update their personal data when it is inaccurate or incomplete for the purpose of processing it;
- right to be deleted (right to be forgotten) when the data is processed illegally or on an expunged basis (the original purpose for which they were collected and processed, expired (incl. Statute of limitation), consent for withdrawal is fulfilled processing, you objected to their processing, etc.), there is no other justification for processing them, or national or European law requires this;
- right to limit processing - in the presence of a legal dispute between Hot Bel-BG EOOD and the individual pending its resolution and / or for the establishment, exercise or defense of legal claims; where the processing is unlawful but the data subject does not wish to have the personal data erased but requests instead to restrict their use; if you object to the processing of your personal data for the duration of its validity check;
- right to data portability - the data subject has the right to ask us to transfer his personal data in machine-readable format to another explicitly specified controller by him without hindrance;
- an obligation to notify when correcting or deleting personal data or limiting processing, the customer has the right to require us to notify third parties to whom his personal data have been disclosed, of any deletion, correction or blocking of such data, except in the cases, when this is not possible or is associated with excessive efforts for HOT BEL-BG EOOD.
- the right to be informed about personal data breach - in cases where data breach is likely to create a high risk to the rights and freedoms of individuals. We do not have to inform you if: we have taken appropriate technical and organizational safeguards with respect to data affected by the security breach, and if we have subsequently taken measures to ensure that the breach will not lead to a high risk of your rights and if the notification would require a disproportionate effort.
- the right to object to the processing of your personal data - at any time and on grounds relating to the individual's particular situation, provided that there are no compelling legal grounds for processing that take priority over the interests, rights and freedoms of the subject data, or lawsuit.
- right to judicial and administrative redress - the right to file a complaint with a supervisory authority, the right to effective judicial protection against a supervisory authority, the right to an effective judicial protection against an administrator or processor; the right to compensation for the damage suffered.
Rights Exercise Order: You can exercise all your rights regarding the protection of your personal data by submitting an application in any form that contains a statement to that effect and identifies you as the data owner. HOT BEL-BG EOOD shall consider and decide upon the request of the User in accordance with the requirements of the applicable legislation as soon as possible and in all cases within 1 / one / month from the receipt of the application. If necessary, this period may be extended by another 2 / two / months, given the complexity and number of applications. HOT BEL-BG EOOD shall inform the consumer of any such extension within one month of receipt of the application, indicating the reasons for the delay. Details of the inspection body:
PERSONAL DATA PROTECTION COMMISSION / CPDP /, 1592 Sofia, “Prof. Tsvetan Lazarov 2, tel .: 02 / 91-53-518, fax: 02 / 91-53-525, e-mail: kzld@cpdp.bg; www.cpdp.bg
6. Can you refuse to provide personal data to HOT BEL-BG EOOD and what are the consequences of this?
In order to fulfill your reservation and to provide you with the requested accommodation services in our hotel, we need certain information, which is regulated by the legislation in force in the Republic of Bulgaria. Failure to provide those referred to in 2.1. personal data prevents Hot Bel-BG Ltd. from accepting your reservation and accordingly providing you the requested services on-site at our hotel.
7. Our cookie policy: Our customers should be informed that information and data can be collected automatically through the standard functioning of Internet servers and the use of cookies. The information and data thus collected do not constitute personal data within the meaning of the Regulation.
8. CHANGES TO THE HOLD BEL-BG EOOD PRIVACY POLICY shall have the right, when circumstances require, to unilaterally update, amend and supplement the privacy policy at any time in the future. Any amendment or modification of this Policy will be posted on the website of Hot Bel-BG EOOD and / or made available upon request.
This policy was last updated on Sept 20, 2019.