PRIVACY POLICY AND PROTECTION OF PERSONAL DATA
on
“Property Management Services” EOOD
regarding the provision of hotel services in guest apartments
The instruction aims to protect the interests of customers – individuals and legal entities from illegal and dishonest processing of their personal data.
Aware of the importance of protecting the personal data of our customers and partners, we strive to maintain good policies and practices ensuring the maximum protection of your personal data processed during and/or on the occasion of providing basic and/or additional tourist accommodation services, as well as other services provided on site in the apartments managed by us.
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 amendments and additions to the Privacy Policy will be applied after updating the publication of its current content, where available.
The privacy policy is applicable to your personal data if you are a natural person or a representative of a legal entity that uses or wishes to use the services provided in the apartments managed by “Property Management Services” EOOD, including those offered online through our partners.
1. Who processes and is responsible for your personal data:
“Property Management Services” EOOD is a commercial company registered in the Commercial Register at the Registration Agency with EIK 102919786, 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.
“Property Management Services” EOOD is a personal data administrator within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and the Personal Data Protection Act.
For all questions related to the processing of your personal data, you can contact us at:
email: reservations@pmgroup.bg reservations2@pmgroup.bg
phone: +359896706664; +359894350333
2. What data, for what purposes and on what legal basis do we process:
2.1 Depending on the specific goals and grounds, “Property Management Services” EOOD processes the following data independently or in combination with each other, namely:
A) Data provided by you, necessary for identification and fulfillment of reservations made and confirmed by you, such as:
• three names, telephone and/or e-mail address for contacting you, or contact person specified by you, date and time of check-in and departure, children and their ages;
• data collected when payment is made to us – credit or debit card data, bank account and other information collected and processed in connection with making a payment by bank transfer, through a Pos-terminal or Key-entry terminal.
• other data that you provide us in connection with the services already used or about your preferences for our apartments.
B) Physical identity data provided by you to “Property Management Services” EOOD in the process of providing accommodation services, which data is collected, processed and stored in accordance with the current regulatory requirements regarding the keeping of a register of accommodated tourists by the persons carrying out hospitality, namely:
• names of the person; Social security number /for Bulgarian citizens/ or Personal Number /for foreign citizens with a residence permit in Bulgaria/, or date of birth /in all other cases/;
• gender;
• nationality;
• ID card number/valid national identity document, country that issued the national document.
The data collected for the purposes of registration at the place of accommodation are collected on the basis of Art. 6, par. “C” of the OZRD – for the fulfilment of a legal obligation that applies to “Property Management Services” EOOD, namely – art. 116, para. 2 of the Law on Tourism – for the purposes of keeping a register of accommodated tourists.
They are stored within the statutory period.
C) Others:
• IP address when visiting our website;
• Data in connection with a complaint made regarding a tourist service provided by us and used by you;
• information about the type and content of your booking and any other information related to it, including e-mails, letters, requests, complaints and other feedback we receive from you;
2.2. Purposes and legal grounds for processing personal data:
A leading basis for processing and storing personal data is the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to the conclusion of such a contract. At the same time, the processing of certain personal data is necessary to comply with the company’s legal obligations in accordance with the Law on Tourism, the Law on Civil Registration, the Law on Accounting and other applicable regulations, as well as for the protection of the legitimate interests of “Property Management Services” EOOD or to a third party, such as:
A) Processing and storage of personal data that are minimally necessary and legally required for the purposes of providing tourist accommodation services, as well as for all other services related to the stay such as:
• Customer identification when: making, changing and canceling a reservation; in the provision of tourist accommodation services; on all other services provided on site in connection with your stay. Customer identification is carried out through all commercial and communication channels – through company employees occupying positions of accommodation and dispatch of guests by providing an identity document, by phone, on online platforms of partners, by e-mail, etc.;
• Updating personal data or service information upon your request for correction/change of data/services;
• Handling and responding to customer complaints/queries/complaints. Corrections of amounts due for already made accommodation reservations if there is a reason for this;
B) In fulfillment of its legal obligations, “Property Management Services” EOOD processes your data for the following purposes:
• Provision of information to the Ministry of Internal Affairs, Nessebar Municipality, the Consumer Protection Commission and the Personal Data Protection Commission in connection with the fulfillment of obligations as a hotelier, resulting from the current regulations in this area;
• processing the data in invoices issued in your name for purposes compatible with the original purpose of their collection;
• Carrying out tax and insurance control by the relevant competent state authorities;
• Provision of information to third parties within the framework of obligations of a legal nature, in proceedings before a court, in order to protect one’s legal interests, including collection of receivables from customers by court order;
C) “Property Management Services” EOOD also processes your data for the purposes of our following interests:
• for the purposes of direct marketing – sending offers containing information about our current offers, promotions and discounts for accommodation in our hotels and/or changes in the conditions of those already used;
3. Categories of third parties who receive access to and process your personal data: In connection with carrying out its activities and fulfilling our contractual commitments with our clients, “Property Management Services” EOOD provides your data to the following groups of persons “recipients”, and namely:
• to the data subject – whenever they exercise this right;
• the users/customers to whom the data refer;
• to business partners – for the purposes of fulfilling your reservations: travel agents and representatives in Bulgaria and abroad, transport companies or other subcontractors with whom we have concluded contracts;
• payment service providers for online payment by credit cards;
• insurance companies when declaring an insured event with a tourist;
• IT companies supporting information systems, our company website, software and platforms for managing our customers’ reservations, etc.;
• of public bodies (Ministry of Internal Affairs, Municipality, NRA, Commission for Consumer Protection, Commission for Protection of Personal Data, judicial and other control bodies);
• When we hold personal information about you, we may disclose data to third parties who may also hold information about you. These can be companies serving common areas in the complexes, some of which are properties serviced by “Property Management Services” EOOD, hotel receptions, etc.
“Property Management Services” EOOD observes the principle of prohibiting the processing of special categories of data (disclosure of racial or ethnic origin; disclosure of political, religious or philosophical beliefs; membership in political parties or organizations; associations with religious, philosophical, political or trade union purposes; personal data that relate to sex life).
We may be required – by law, in litigation and/or at the request of public and governmental authorities in or outside your country of residence, as well as for the purposes of national security, law enforcement or other matters of public concern, to we disclose your personal data when such disclosure is necessary or appropriate.
We may also disclose information about you if we determine that such disclosure is reasonable and necessary to enforce our company terms and conditions, or to protect our activities, legitimate interests, and the rights and legitimate interests of other clients. In addition, in the event of a reorganization, merger or sale, we may transfer any and all collected database to the applicable third party transferee.
4. For what period are your personal data stored. Security:
The duration of storage of your personal data depends on the processing purposes for which they were collected:
Your personal data, processed for the purpose of providing and performing tourist accommodation services, are stored for a period of up to 3 (three) years, starting from the date of your departure from the hotel, as well as until the final settlement of all financial relations between the parties, in compliance with the legally defined deadlines, if any;
Personal data processed for the purpose of issuing accounting/financial documents for the implementation of tax and insurance control, as well as but not limited to – invoices, debit, credit notices are stored for at least 3 (three) years, unless the applicable legislation provides for a longer period.
The storage of personal data for longer periods is possible to protect the legal interests of “Property Management Services” EOOD, as well as until the expiration of the relevant statute of limitations in order to protect against possible customer claims in connection with the implementation/termination of the provided tourist services under accommodation, as well as for a longer period in case of a legal dispute that has already arisen – the documents are kept until its final resolution with an effective court/arbitration decision.
As the Administrator of personal data – “Property Management Services” EOOD takes care and undertakes the relevant administrative, technical and physical measures required by the regulations, as well as those related to personnel /training, awareness, etc./ in order to protect the information, at its disposal, including protecting the personal data of its customers from loss, theft and unauthorized use, disclosure, modification and any other illegal forms of processing. We have physical, electronic and procedural safeguards in place that comply with our legal obligations to protect personal data.
“Property Management Services” EOOD is responsible for the protection of the client’s personal data, in connection with the implementation of our activity as a hotelier and when providing the tourist services offered by us, except in cases of force majeure, accidental event or malicious actions of third parties, as well as in cases where the customer himself has made this information available to third parties.
5. What are your rights in relation to the processing of your personal data by “Property Management Services” EOOD and what actions should you take to exercise them:
• right of access to the data concerning him – the customer has the right at any time to request confirmation of whether data concerning him is being processed, information about the purposes of this processing, about the categories of data and about the recipients or categories of recipients, of which data is disclosed;
• right to correct and update your personal data when they are inaccurate or incomplete in view of the purposes of their processing;
• right to deletion (the right to be forgotten) when his data is processed unlawfully or for no reason (the original purpose for which they were collected and processed has been fulfilled, the storage period has expired (including statute of limitations), consent has been withdrawn for processing, you have objected to their processing, etc.), there is no other reason for their processing or national or European legislation requires it;
• right to restrict processing – in the event of a legal dispute between “Property Management Services” EOOD and the individual until 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 the personal data to be deleted, but instead requests the restriction of its use; in the event of your objection to the processing of your personal data for the period of the verification of its validity;
• right to data portability – the data subject has the right to request us to transfer his personal data in a machine-readable format to another controller explicitly indicated by him without hindrance;
• obligation to notify in case of correction or deletion of personal data or restriction of processing – the client has the right to demand from “Property Management Services” EOOD to notify the third parties to whom his personal data has been disclosed, of any deletion, correction or blocking of these data, except for cases where this is impossible or involves excessive efforts for “Property Management Services” EOOD.
• the right to be notified of a breach of personal data security – in cases where there is a possibility that the breach of data security will create a high risk for the rights and freedoms of natural persons. “Property Management Services” EOOD is not obliged to notify you if: we have taken appropriate technical and organizational measures to protect the data affected by the security breach, as well as if we have subsequently taken measures to ensure that the breach will not would result in a high risk to your rights and if notification would require a disproportionate effort.
• right to object to the processing of your personal data – at any time and on grounds related to the specific situation of the person, provided that there are no compelling legal grounds for the processing that take precedence over the interests, rights and freedoms of the subject of data, or litigation.
When personal data are processed for the purposes of direct marketing, you have the right at any time to object to the processing of personal data concerning you for this type of marketing, which includes profiling as far as it is related to direct marketing. At the latest at the time of the first contact with the user, he is expressly informed of the existence of the right of objection described above, which is provided to him by notification in a clear way and separately from any other information.
• the right to legal and administrative protection – the right to file a complaint with a supervisory authority.
Procedure for exercising rights: You can exercise all your rights regarding the protection of your personal data through the forms attached to this Policy. Of course, these forms are not mandatory and you can make your requests in any form that contains a statement to that effect and identifies you as the data owner.
“Property Management Services” EOOD examines and decides on the request of the User in accordance with the requirements of the applicable legislation in the shortest possible time and in all cases within 1 /one/ month from the receipt of the application. If necessary, this term can be extended by another 2 /two/ months, given the complexity and number of applications. “Property Management Services” EOOD informs the user of any such extension within one month of receiving the application, indicating the reasons for the delay.
Details of the supervisory authority:
COMMISSION FOR THE PROTECTION OF PERSONAL DATA /KZLD/,
Sofia 1592, “Prof. Tsvetan Lazarov” Blvd. No. 2,
phone: 02/91-53-518, fax: 02/91-53-525,
e-mail: kzld@cpdp.bg
www.cpdp.bg
6. Can you refuse the provision of personal data to “Property Management Services” EOOD and what are the consequences of this?
In order to fulfill your reservation and to provide you with the accommodation services requested by you in our hotels, Property Management Services” EOOD needs certain data, which are normatively determined by the legislation in force in the Republic of Bulgaria.
Failure to provide the items specified in item 2.1. personal data prevents the possibility of “Property Management Services” EOOD to accept your reservation and, accordingly, to provide you with the requested services on the spot in our hotels.
“Property Management Services” EOOD has the right, when the circumstances require it, to unilaterally update, amend and supplement the personal data protection policy at any time in the future. Any addition or change to this Policy will be posted in all places where this policy is published or will be made available upon request to the Customer.
This policy was last updated on 05/21/2018.
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