Last updated: February 25, 2024

This document contains the Personal Data Protection Policy of “AS Hoteli” EOOD—registered in the Commercial Register at the Registry Agency under Unified Identification Code (UIC) 131261782, with its registered office and management address at 33 Trakia St., Sofia 1504, and a scope of business covering hotel and restaurant operations as well as additional tourism services (the “Policy”)—and constitutes an integral part of the General Terms and Conditions for the use of the website of Hotel Belvedere (the “Hotel”). If you do not agree to these Terms and Conditions, you will not be able to use the website. In the event of any changes to the Policy, such changes will be published here.

For the purpose of providing tourism services (“Services”) on the website https://hotelbelvedere-bg.com (the “Website”), AS Hoteli EOOD processes the personal data of natural persons—hotel clients or other individuals specified below (“Data Subjects”/“You”)—in accordance with this Policy.

When processing personal data, AS Hoteli EOOD complies with all legal acts regarding personal data protection applicable to its activities, including, but not limited to, Regulation (EU) 2016/679 (the “Regulation”).

Definitions:

• personal data is any information that relates to you and by means of which you can be identified, directly or indirectly;
• обработване на лични данни („Обработване”) е всяко действие или съвкупност от действия, които могат да се извършат по отношение на личните данни с автоматични или други средства.

1. Purposes of Personal Data Processing

AS Hoteli EOOD collects the data provided by you in connection with the conclusion of a contract for the use of the hotel’s services, the documentation of personal data processing activities, the fulfillment of the controller’s legal obligations, and the protection of legitimate interests in accordance with applicable legislation:

1.1. Conclusion and performance of a contract. These purposes relate to the steps necessary for concluding and executing the contract between you and the hotel, including the data processing required for registration, account creation, and the provision of services available through the Site. Furthermore, these purposes encompass communication with you—including via email—necessary for the provision of the Services and/or for notifying you of any changes to the Services provided. Achieving these purposes may require the processing of some or all of the categories of data mentioned above.

1.2. Legitimate interest. The purposes of the legitimate interests of AS Hoteli EOOD (and its subcontractors or service providers) include:

• Ensuring the normal functioning and use of the Site by you and other users, maintenance and administration of the Services, resolution of disputes, and detection and prevention of malicious activities;
• Communicating with you, including by electronic means, regarding important matters related to the Services;
• Receipt and processing of received reports, complaints, requests, and other correspondence;
• The exercise and protection of the rights and legitimate interests of AS Hoteli EOOD, including through judicial proceedings, and the provision of assistance in the exercise and protection of the rights and legitimate interests of other users of the website and/or affected third parties.

1.3. Законови задължения. These are goals such as:

• Financial and accounting activities involving the processing and storage of information required by law for the fulfillment of tax, accounting, and other reporting obligations;
• Activities related to the fulfillment of obligations provided for by law to retain or provide information;
• Activities related to the fulfillment of documentation and reporting obligations, as well as other obligations associated with compliance with the requirements of Regulation (EU) 2016/679 and applicable legislation—including those arising from the Personal Data Processing Agreement and other applicable requirements.

1.4. Изрично съгласие. Your data may be processed on the basis of your explicit consent; in such cases, the processing is specific and limited to the extent and scope provided for in the relevant consent.

AS Hoteli EOOD processes personal data solely in accordance with this Policy and to the extent permitted by law. Information is collected when you register on the website, make a reservation, subscribe to our materials, provide responses, inquiries, or comments, or enter specific details into a form.

2. Personal data collected, stored, and processed. Retention period

Performance of the contract by the Tour Operator. Up to 5 years from the date of termination of the contract.

		Personal Data Purpose Retention Period
		Conclusion and performance of the contract with the hotel, legitimate interest – Up to 5 years from the date of termination of the contract
		Conclusion and performance of the contract with the hotel, legitimate interest – Up to 5 years from the date of termination of the contract
		ID card, passport; Conclusion and performance of the contract with the hotel, legitimate interest; Up to 5 years from the date of termination of the contract
		Address, telephone number, email; conclusion and performance of the contract with the hotel, including the receipt and processing of complaints and reports, improving the quality of services provided by the hotel, legitimate interest; up to 5 years from the date of termination of the contract.
		Other data provided by you voluntarily | Performance of the contract by the hotel | Up to 5 years from the date of termination of the contract
		Data of persons under 18 years of age.
		Logs of website usage; performance of the contract by the hotel. Up to 1 year from the date of recording.

The website can be used without the need for registration or the provision of any data by the user.

The personal data provided by you will be processed for the purposes of providing tourist information and details regarding services, as well as for personalizing the website to suit your needs and for improving the website. AS Hoteli EOOD may share some of the data received with third parties in connection with the fulfillment of your requests, inquiries, and orders.

The services provided on this website are intended for individuals who have reached the age of 18. AS Hoteli EOOD does not collect, use, or disclose the personal data of minors without the prior consent of a parent or guardian. AS Hoteli EOOD declares that it complies with legislation regarding the protection of children.

3. Rights regarding personal data

As an individual—a data subject—you have the following rights:

3.1. Right to be informed.

This Policy aims to provide you with detailed information regarding the processing of your personal data in connection with the Services provided.

3.2. Right of access.

You have the right to obtain confirmation as to whether your personal data are being processed, access to such data, and information regarding their processing and your rights in relation thereto.

3.3. Right to rectification.

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

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

3.4. Right to erasure.

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

3.5. Right to restriction of data processing.

The Regulation provides for the possibility to restrict the processing of your personal data, if grounds for doing so, as set out therein, are present.

3.6. Right to notify third parties.

Where applicable, you have the right to request that AS Hoteli EOOD notify third parties, to whom it has disclosed your data, regarding the rectification, erasure, 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 concerns you in a structured, machine-readable format, and to use this data with another controller at your own discretion.

3.8. 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, unless the grounds for doing so provided for in applicable data protection legislation exist and appropriate safeguards are in place to protect your rights, freedoms, and legitimate interests.

При предоставяне на Услугите в Сайта не се използват технологии, попадащи в тази категория.

3.9. Right to withdraw consent.

You have the right, at any time, to withdraw your consent for the processing of personal data that is based on consent you have provided. Such a withdrawal does not affect the lawfulness of processing based on the consent given prior to its withdrawal.

Data provided on the legal basis of consent includes: information regarding food preferences, allergies, and any other details you choose to provide, which are not required by AS Hoteli EOOD for the conclusion of the contract for tourist services.

3.10. Right to object.

Вие имате право да възразите по отношение на данни, обработвани на базата на легитимен интерес.

Should such an objection be received, We will review your request and, if it is well-founded, We will comply with it. If We determine 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 accordingly.

3.11. Право на жалба до надзорен орган.

You have the right to lodge a complaint with a supervisory authority if you believe that the processing of personal data relating to you violates applicable personal data protection legislation. The supervisory authority in the Republic of Bulgaria is the Commission for Personal Data Protection, located at: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.

4. Data Protection Officer.

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

и-мейл:

phone:

address:

5. НЕРАЗКРИВАНЕ НА ЛИЧНИ ДАННИ

AS Hoteli EOOD collects personal data solely in accordance with legislation regarding the protection of personal data. Except in the cases provided for in this Policy, personal data will not be disclosed to other third parties. When it is necessary to provide your personal data to contractors of AS Hoteli EOOD in connection with the provision of services, such data will be processed exclusively in compliance with legal requirements and in relation to the requested services.

Certain personal data may be disclosed to competent authorities pursuant to a law, court decision, or other valid legal instrument, and/or if such disclosure is necessary for the detection of crimes within the country and/or abroad.

6. RESPONSIBILITY

АС Хотели ЕООД не носи отговорност за политиките за обработване на лични данни на уебстраници, към които съдържа препратки тази уебстраница.

7. CONFIDENTIALITY

When processing personal data, AS Hoteli EOOD takes all necessary measures to protect the information against loss, misuse, disclosure, alteration, or destruction, as well as against disclosure to unauthorized third parties.