The Policy is drafted in compliance with the requirements under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the Regulation).
Art. 1. In connection with the provision of its services and performance of its activities, SUITE HOTEL SOFIA LTD (SUITE HOTEL SOFIA), in its capacity as data controller, processes personal data of its customers – natural persons, as well as personal data of other individuals specified below (“Data Subjects”/“you”), in compliance with the rules and principles under the present Policy.
Art. 2. SUITE HOTEL SOFIA LTD is a company with UIC 130956934, head office and registered address: 1700 Sofia, Studentski grad district, 1A Yordan Yossifov str., tel.: (+359) 24458090, email address: firstname.lastname@example.org, VAT number: BG130956934.
Art. 3. (1) In connection with the provided services SUITE HOTEL SOFIA processes information regarding the following Data Subjects:
(a) Natural persons visiting the website http://suitehotelsofia.bg/(the Website);
(b) Natural persons making reservations through the Website, in their name or on behalf of another natural person or legal entity;
(c) Natural persons using the services provided by SUITE HOTEL SOFIA, including, but not limited to, hotel accommodation, restaurant and related services, provision of conference and event halls, etc., as well as natural persons representing or acting in another manner on behalf of legal persons using the said services;
(d) Natural persons who, on their own behalf or on behalf of another person, have addressed inquiries (including, but not limited, by email, fax, phone, using the Instant Messagingfunctionality on the Website and others), requests, signals, complaints or other correspondence to SUITE HOTEL SOFIA;
(e) Natural persons concerning whom information is contained in inquiries, requests, signals, complaints or other correspondence addressed to SUITE HOTEL SOFIA (including by phone or using the Instant Messagingfunctionality on the Website).
(2) Services provided by SUITE HOTEL SOFIA may be ordered only by legally capable persons who are 18 years old or older.
Personal data categories
Art. 4. The information (categories of personal data) concerning Data Subjects which is processed by SUITE HOTEL SOFIA pursuant to the present Policy may include:
1. In connection with the provision of hotel accommodation services:
(a) Identification data: guest’s full name; date of birth; gender; nationality; national identification number (such as PIN for Bulgarian citizens) and/or ID document number; ID document date of issue; ID document date of expiry; country issuing the ID document; signature.
(b) Contact details: telephone number; email address; address.
(c) Information related to hotel accommodation: room number; floor; dates of stay (check-in date, check-out date); duration of stay (number of nightsspent at the hotel); tourist package, if used; type of room preferences (smokers/non-smokers); VIP guest’s status;
(d) Additional information related to hotel accommodation at the customer’s explicit request: special requirements and preferences, including type of press, food and drinks; special requirements related to food products, drinks and other substances which should be avoided by the guest (regardless of the reason).
2.Data relating to payments and issuance of invoices: information regarding the payment method (in cash, by bank transfer, by credit card, etc.); information regarding due and effected payments; information regarding the due date of payment and overdue/outstanding debts; bank details (bank, IBAN, account holder); currency of the payment; number, expiry date and holder of the credit/ debit card; CVC code; data contained in the payment authorization slip; name of the legal person; address of the legal person; VAT number and/or other identification, tax or registration number (PIN for natural persons); authorization slips (signed).
3. In connection with the provision of restaurant services:
(a) Identification data: full name.
(b) Contact details: telephone number; email address; address.
(c) Data relating to payments and issuance of invoices: number, expiry date and holder of the credit/debit card; CVC code; name of the legal person; address of the legal person; VAT number and/or other tax or registration number (for sole traders and natural persons); authorization slips (signed).
(d) Information of preferences (at the customer’s explicit request): food and drink preferences; preferred payment method; specific requirements related to food products, drinks and other substances which should be avoided by the guest (regardless of the reason).
4. In cases where the Data Subject represents another person (e.g. a company): information regarding the represented person and the capacity of the representative (incl. workplace, position), as well as information of ordered services/ submitted orders in such capacity. Respectively, in cases where the services are ordered by a person other than the Data Subject on behalf of the Data Subject – in what capacity the Data Subject will use the services, who has ordered the services, who will make the payment, etc. (for instance, in case of accommodations organized by an employer or a business partner of the Data Subject, etc.).
5. In connection with the issuance of loyalty cards:
(a) Identification data: full name.
(b) Information regarding the discount which can be used with the respective loyalty card.
6. In connection with the services and functionalities of the Website:
(a) Data processed in connection with accommodation booking:full name, email address; telephone number; country; number, expiry date and holder of the credit/ debit card; CVC code; number of rooms; number of guests, including number of adults and number of children; corporate code/ access code; code of the participant in an event and/or group accommodation; booking number; special offers and preferences (with explicit indication in the booking form); package data (e.g. FAMILY BREAK IN SOFIA package, special occasion package, etc.).
(b) Non-structured content from conversations with and inquiries to a booking agent through the Instant Messagingfunctionality on the Website.
(c) Information from log-in logs, server logs, Web Application Firewalls, and other devices falling in this category: date and time, IP address, URL, browser and device information.
7.In connection with complaints, applications, requests and signals (including in free text): non-structured information contained in the respective complaints, applications, requests and signals.
Surveillance and security
Art. 5. (1) Under the requirements of the applicable legislation, SUITE HOTEL SOFIA applies security measures including the following technical and organizational means for access control, for ensuring the physical security against violations on the buildings and sites, and for protection of the life and health of citizens: security guards, alarm systems, a 24-hour video surveillance system of recording and storage devices.
(2)Video surveillance and video recording may be performed in publicly accessible zones and premises in the buildings of SUITE HOTEL SOFIA, and in zones and premises with an exclusive access regime. There is no video surveillance in the guest rooms, WCs, recreation rooms, etc. The data of video surveillance activities are stored in a monitoring room with limited access and 24-hour security.
(3)Information boards are available at visible places to notify Data Subjects and other visitors that technical means for surveillance and control are used, and provide any other related information.
Art. 6. (1)Subject to the Data Subject’s explicit consent, SUITE HOTEL SOFIA, respectively other companies related to or partners of SUITE HOTEL SOFIA, may process the following personal data: names; telephone number; address; email address; information of the type and number of used and preferredservices provided by SUITE HOTEL SOFIA, and other data explicitly specified in the respective consent for the purposes of direct marketing, such as offering of goods and services, including goods and/or services offered by other persons, conducting inquiries and polls for the purpose of improving the quality of the services provided, etc., within the scope of the respective consent.
(2) Where personal data are processed for direct marketing purposes, the Data Subject shall be entitled at any time to object to such processing. In such cases, the processing of personal data for such purposes is terminated.
(3) The Data Subject shall be entitled at any time to withdraw his/her consent to the processing ofhis/her personal data for direct marketing purposes. In such cases, the personal data processing based on that consent is terminated.
(4) Profiling for the purposes of direct marketing may be carried out only based on the Data Subject’s explicit consent, subject to at least the following additional guarantees for their rights and interests: the right to human intervention by the data controller; the right to express their point of view and the right to challenge the decisions based on profiling. At present, SUITE HOTEL SOFIA does not perform such processing of personal data.
Purposes of personal data processing
Art. 7. SUITE HOTEL SOFIA collects, stores, and processes the information described in Art. 4, 5, and 6 above for the purposes provided for in the present Policy and in the General Terms (the contract) for use of the services provided. Depending on the legal grounds for the processing, those purposes may be:
(a) purposes related to the compliance with legal obligations of SUITE HOTEL SOFIA;
(b) purposes related to and/or necessary for the performance of the contracts concluded with SUITE HOTEL SOFIA or for taking steps at the request of the Data Subject prior to entering into a contract;
(c) purposes related to the legitimate interest of SUITE HOTEL SOFIA and third parties;
(d) purposes for which the Data Subject has given his/her consent to the processing of his/her data.
Art. 8.The purposes of personal data processing carried out by SUITE HOTEL SOFIA related to the compliance with legal requirements include:
1. keeping a register of accommodated guests and providing information from that register to the competent authorities, as legally required;
2. address registration of foreigners in compliance with the requirements of the applicable legislation;
3. deduction and payment of tourist tax;
4. activities related to the development and implementation of counter-terrorism measures;
5. handling of signals, complaints, requests for exercising of rights, etc., as well as claims and commercial guarantees (if applicable), including preparation of the relevant replies thereto;
6. bookkeeping, invoicing and accounting of incoming and outgoing payments in compliance with the applicable tax and accountancy legislation;
7. other activities related to the fulfilment of SUITE HOTEL SOFIA’s legal obligations (tax, accounting, regulatory, licensing, etc.) requiring the provision of information to and cooperation with the competent state and judicial authorities upon performance of inspections.
Art. 9.The purposes of personal data processing carried out by SUITE HOTEL SOFIA related to and/or necessary for the performance of contracts or for taking steps at the request of the Data Subject prior to entering into a contract with SUITE HOTEL SOFIA include:
1. receipt, administration and processing of bookings, including cancelled bookings;
2. customer services, including provision of online services through the Website;
3. communication related to the provision of services;
4. administration and receipt of payments for the services provided, including remotely;
5. ensuring a guarantee for bookings and payments of hotel accommodation and any extra services requested;
6. financial and accounting activity and administration, processing and collection of due payments for the services provided;
7. refunding of incorrectly transferred amounts;
8. ensuring an individual approach in the provision of the services, taking account of the explicitly specified preferences of the customer.
Art. 10. The purposes related to the legitimate interests of SUITE HOTEL SOFIA and third parties include:
1. Legitimate interest – (1.1.) exercise and protection of the rights and legitimate interests of SUITE HOTEL SOFIA; and (1.2.) assistance in the exercise and protection of the rights and legitimate interests of customers; of other persons related to SUITE HOTEL SOFIA; of employees of SUITE HOTEL SOFIA; of data processors processing personal data on behalf of SUITE HOTEL SOFIA; and of business partners of SUITE HOTEL SOFIA:
(a) establishment, exercise or defence of legal claims of the persons specified above under items (1.1) and (1.2), including by legal proceedingsand filing of complaints, signals, etc. with the competent state and judicial authorities;
(b) video surveillance and access control ensuring the security of SUITE HOTEL SOFIA’s property, proving the compliance with applicable requirements, ensuring the physical security against violations on the buildings and objects, and protection of the life and health of citizens;
(c) taking actions for suspending the services provision in case of refusal of payment, violations of SUITE HOTEL SOFIA’s established rules and policies, etc.;
(d) administration and handling of submitted complaints, signals, requests, etc.;
(e) collection of debts due to SUITE HOTEL SOFIA, including by execution proceedings and/or through assignment to third parties, as well as by transfer of debts to third parties (cessions) following the statutory procedure;
(f) submission of notary invitations.
2. Legitimate interest – analysis, planning and improving the quality of services provided by SUITE HOTEL SOFIA:
(a) keeping a backup copy of the data in the internal information system regarding the current state of the hotel (occupation/ availability of rooms, obligations, etc.) in case of information systems failure;
(b) receipt, handling, and preparation of replies to submitted applications, requests, etc. which are not related to claims and complaints concerning the services used;
(c) survey of the customers’ satisfaction with the services;
(d) control, analysis, and optimization of the business processes for improvement of the quality of services.
3. Legitimate interest – ensuring the normal functioning and use of the Website:
(a) maintenance and administration of the Website;
(b) detection and repair of technical problems in the Website’s functionalities;
(c) taking measures against malicious actions against the security and normal functioning of the Website.
4. Legitimate interest – hotel accommodation and restaurant activities, provision of professional hotel and restaurant services:
(a) administration and management of the services provided by SUITE HOTEL SOFIA;
(b) quality management and control of the services provided;
(c) receiving feedback on the services provided.
Art. 11.The purposes of personal data processing based on consent given by the Data Subject include:
1. Sending marketing and advertising communications regarding services, exclusive offers, packages, events, etc.
2. Surveys and receiving feedback on the quality of services;
3. Sending newsletters;
4. Other purposes for which the Data Subject has explicitly given his/her consent.
Provision of personal data and consequences from refusal to provide such data to SUITE HOTEL SOFIA
Art. 12. (1) SUITE HOTEL SOFIA clearly indicates, where applicable and in the appropriate manner, whether the provision of the respective data and/ or documents is mandatory or constitutes a requirement necessary for the conclusion or performance of a contract, as well as the consequences from the refusal to provide such data.
(2)If needed, any Data Subject may request further clarifications at the premises of SUITE HOTEL SOFIA or by addressing respective query to the contact details specified in Art. 23 of the present Policy.
(3)Any refusal to provide data and documents indicated as mandatory may prove an impediment to the provision of a service by SUITE HOTEL SOFIA, to the satisfaction and execution of submitted requests, applications, signals, etc., which releases SUITE HOTEL SOFIA from liability for default.
(4)Any refusal to provide data and documents or any provision of false data may entail failure to provide the respective services or suspension of the access to services provided by SUITE HOTEL SOFIA.
(5)Data Subjects shall not provide SUITE HOTEL SOFIA with any special categories of data within the meaning of Art. 9 and Art. 10 of the Regulation (namely: personal data revealing racial or ethnic origin, political opinion, religion or philosophical beliefs, trade union membership, genetic data, biometric data, health status, or sexual life or orientation of the natural person; and personal data related to criminal convictions and offences).
Other sources of personal data
Art. 13. (1) In certain cases, the personal data processed by SUITE HOTEL SOFIA are not collected and received directly from the Data Subject of the relevant data, but from third parties, such as:
1. Persons representing, working for or otherwise cooperating with the Data Subject;
2. Event organizers – with respect to information concerning the participants in the event;
3. Business partners (e.g. booking sites as booking.com; tourist agencies, other persons that provide intermediary services in the context of booking or ordering of other services, etc.) of SUITE HOTEL SOFIA;
4. Competent state and judicial authorities.
(2) The persons under Para. 1, items 1-3 shall inform the Data Subjects whose data are provided to SUITE HOTEL SOFIA of the fact of the data provision, the purposes and scope of such data provision, shall introduce the Data Subjects to the present Policy, andshall guarantee that they provide the data on valid legal grounds.
Processing of information by third parties – data processors
Art. 14. (1) For the purposes specified in the present Policy, SUITE HOTEL SOFIA may assign data processing activities to third parties– data processors, in compliance with the requirements under the Regulation and the other applicable personal data protection rules.
(2)Where personal data are disclosed to and processed by data processors, such disclosure and processing will be carried out only to the extent and in the amount necessary for the performance of the tasks assigned by SUITE HOTEL SOFIA.
(3)Data processors act on behalf of SUITE HOTEL SOFIA and are obliged to process personal data only in strict compliance with SUITE HOTEL SOFIA’s instructions. Data processors shall not be entitled to use or otherwise process the information for purposes other than for the purposes specified in the present Policy.
Categories of recipients of personal data
Art. 15.SUITE HOTEL SOFIAdoes not disclose personal data concerning the Data Subject to third parties except where:
1. this is necessary for compliance with a legal obligation of SUITE HOTEL SOFIA:
(a) competent state, municipal or judicial authorities;
(a)data processors as assigned by SUITE HOTEL SOFIA;
(b) companies for accounts receivable collection.
3. this is necessary for the provision of the services of SUITE HOTEL SOFIA:
(a) banks and payment services providers;
(b) postal and delivery services providers;
(c)SUITE HOTEL SOFIA business partners such as: booking sites; travel agencies and other providers of tourist services or other supportive services such as car rental, taxi and other transport services, etc.
4. the Data Subject has given his/her explicit consent – the persons provided for in the relevant consent (e.g. SUITE HOTEL SOFIA related parties, SUITE HOTEL SOFIA business partners, etc.);
5. this is necessary to protect the rights and legitimate interests of SUITE HOTEL SOFIA, third parties or Data Subject:
(a) state, municipal and judicial authorities;
(b) private and public judicial enforcement officers;
(d) notaries public.
6. in other cases provided by law.
Art. 16. (1)SUITE HOTEL SOFIAprocesses and stores information about the Data Subject until achieving the relevant purposes it is collected and processed for.
(2) SUITE HOTEL SOFIA, in accordance with its internal rules and procedures, as well as the applicable legislation, processes and stores information about the Data Subject for the periods as follows:
|Type of data||Storage period|
|Data relating to the register for accommodated tourists within the meaning of Art. 116 of the Tourism Act, including identification data of the accommodated persons as well as data related to the hotel accommodation||In accordance with the procedures and time limits stipulated in the Tourism Act and the relevant regulations|
|Information relating to requested and used hotel accommodation services, events and restaurant services, including such relating to cancellation of bookings for hotel accommodation (as far as they involve a refund of pre-paid amounts and/or a deduction of amounts due)||From making the respective booking/ request up to 5 /five/ years from the provision of the service/ completion of the contract/ cancellation of the booking.
In cases where the services are requested and used based on a long-term contract, the period starts running from the complete performance and/ or termination of the contract.
|Financial and accounting documents; invoices; authorisation slips; other information related to tax and insurance control.||Up to 10 /ten/ years from the beginning of the year following the one in which payment of the amount for the relevant year is due.|
|Unstructured communication, correspondence, complaints, signals, etc.||5 years
In cases where the correspondence concerns a long-term contract, the period starts running from the complete performance and/ or termination of the contract.
|Data relating to reservation of restaurant services by phone||Up to 1 year|
|System logs. Logs related to security, technical support, etc. (these may contain information such as: date and time, IP address, URL, information about the browser version and device)||1 year|
|Data from video recordings||2 months|
|Data from feedback cards||The information from the feedback cards is filled in the internal systems of SUITE HOTEL SOFIA in a fully anonymized form (only the feedback, comments and recommendations) without any information regarding the person who has given this feedback. After that the feedback cards are destroyed immediately. Up to 30 days after they have been filled in|
|Data processed on the grounds of Data Subject’s explicit consent||As of the moment of obtaining the consent till its withdrawal by the Data Subject|
|The personal data referred to in this Policy may also be processed for a longer period than the ones specified above if this is necessary to achieve the objectives set forth therein or to protect the rights and/or legitimate interests (including in legal proceedings) of SUITE HOTEL SOFIA or if the current legislation provides for data processing for a longer period.|
Rights of the Data Subjects regarding their personal data
Art. 17. (1)In relation to the processing of the personal data concerning him/her, each Data Subject has the following rights:
1. Right of information– to be provided with information on the processing of his/her personal data from SUITE HOTEL SOFIA;
2. Right of access:
(a) toobtain confirmation as to whether personal data concerning him/her are being processed;
(b) to have access to the processed personal data and detailed information about its processing and his/her rights.
3. Right of rectification– to require his/her personal data to be rectified and completed if the data are inaccurate or incomplete;
4. Right of erasure– to require his/her personal data to be erased if there are the grounds for this provided for in the Regulation;
5. Right of restriction ofpersonal data processing– to require that SUITE HOTEL SOFIArestricts the processing of his/her personal data within the limits provided for the Regulationif there are the grounds for this set forth therein;
6. Right to notify third parties– to require that SUITE HOTEL SOFIAnotifies the third parties to whom his/her personal data have been disclosed ofany rectification, erasure or restriction of the processing of his/her personal data unless this proves impossible or involves disproportionate effortfrom SUITE HOTEL SOFIA;
7. Right of data portability–to receive the personal data concerning him/her and which he/she has provided, in a structured, commonly used, machine-readable format, as well as to have the right to transmit such data to another controller without any hindrance from SUITE HOTEL SOFIA.
The right of data portability shall apply where both of the following conditions are met:
- processing is based on consent or contractual obligation;
- processing is carried out by automated means.
The Data Subject shall have the right to have the personal data transmitted directly from SUITE HOTEL SOFIA to another controller, where technically feasible. The right of data portability shall be exercised in a manner which does not adversely affect the rights and freedoms of other persons.
8. Rights with regard to automated decision-making, including profiling– not to be subject to an automated decision which is based solely on automated processing (i.е.processing without human intervention), including profiling within the meaning of the Regulationwhich produces legal effects for the Data Subject or similarly significantly affects him/her, unless there are grounds for this as set forth in the Regulation as well as suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests. Such measure shall at least include the right to obtain human intervention on the part of SUITE HOTEL SOFIA, the right of the Data Subject to express his/her point of view and to contest the decision.
If such a decision, including profiling has been made with regard to the Data Subject, the latter shall be entitled to and shall separately be provided by SUITE HOTEL SOFIA with meaningful information about the logic involved, the significance and the envisaged consequences of such processing for him/her, as well as how to exercise the rights under this item.
9. Right to withdraw consentfor processing – where personal data processing is based solely on consent given by the Data Subject, the lattershall have the right to withdraw his/her consent at any time. Such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.
Right to object
Art. 18. The Data Subject shall have the right to object, on grounds relating to his/her particular situation, at any time to processing of personal data concerning him/her, including profiling within the meaning of the Regulation, based on public interest, exercise of official authorityand the legitimate interests of SUITE HOTEL SOFIA or a third party. In these cases, SUITE HOTEL SOFIA shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or where necessary for establishing, exercising or defending legal claims.
Art. 19. (1) The Data Subject may exercise his/her personal data protection rights by personally submitting a written request at the address specified in Art. 23 of this Policyor by sending a notary certified request by post.
(2) The request under Para 1 may also be exercised via electronic means, and for this purpose the same shall be signed by the Data Subject with a qualified electronic signature within the meaning of the Electronic Document and Electronic Certification Services Act and Art. 3 (12) of Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC; which is to be sent to SUITE HOTEL SOFIA at the electronic address referred to in Art. 23 of this Policy.
(3) The Data Subject may exercise the rights relating to his/her personal data either personally or through an explicitly authorised person (with a power of attorney certified by a notary).
(4) Part of the rights may also be exercised through the functionalities available on the Website.
Right to lodge a complaint with a supervisory authority
Art. 20.Any Data Subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State (EU/EEA) of his/her habitual residence, place of work or place of the alleged infringement if the Data Subject considers that the processing of his/her personal data infringes the Regulation or any other applicable data protection requirements.
Supervisory authority in the Republic of Bulgaria
Art. 21. Supervisory authority in the Republic of Bulgaria is:
Commission for Personal Data Protection
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
Restriction of the rights
Art. 22. The scope of the rights of the Data Subjects as well as the obligations of SUITE HOTEL SOFIA in relation to these rights may be restricted by way of a legislative measureunder Union or Member State law to which SUITE HOTEL SOFIA is subject.
Explanations and additional information
Art. 23. The Data Subject may seek clarifications regarding the content, the grounds and the way of exercising his/her rights under this Policy, as well as any additional information regarding his/her rights regarding the processing of personal data by SUITE HOTEL SOFIA on the following contacts:
Address: 1700 Sofia, Studentski grad district, 1A Yordan Yossifov str.
Email address: email@example.com
Telephone: (+359) 24458090