We, HRANINVEST Ltd. are aware of the importance of protecting the personal data of our customers and partners, striving to maintain good policies and practices that ensure maximum protection of your personal data processed during and / or on the occasion of providing basic and / or additional tourist accommodation and catering services, as well as other services provided on site at the hotel, managed by us.
1. Who processes and is responsible for your personal data:
HRANINVEST OOD (“we”) is the company registered in the Commercial Register at the Registry Agency with 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.
HRANINVEST OOD 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 such data and Personal Data Protection Act.
For all questions related to the processing of your personal data, you can contact us at our address of management: 23 Georgi Benkovski Street Plovdiv, Bulgaria or at the following contact details
2. What data, for what purposes and on what legal basis do we process:
2.1 Depending on the specific objectives and grounds, HRANINVEST Ltd. processes the following data individually or in combination with them, namely.
A) Provided by you data necessary for identification and execution of your made and confirmed reservations for any of our Hotel, such as:
three names, telephone number and / or e-mail address for contact with you, or a contact person specified by you, date and time of accommodation and departure, children and their age;
data collected upon payment made to us - credit or debit card number, bank account and other information collected during and processed in connection with the payment by bank transfer, direct debit or through the POS-terminal of "HRANINVEST" Ltd .;
data from your account for access to our online booking platform - username, history of reservations and payments;
data about the services you use and the information obtained through them about your preferred destinations, hotels and services offered by us;
other data you provide to us in connection with the services already used or your preferences for our hotels.
B) Data provided by you and stored by HRANINVEST Ltd. in the process of providing on-site accommodation services in each hotel, which data are collected, processed and stored in accordance with applicable regulations regarding the keeping of a register of accommodated tourists by persons operating hotel business, namely:
names of the person; PIN / for Bulgarian citizens / or LNC / for foreign citizens with a residence permit in BG /, or date of birth / in all other cases /;
identity card number / valid national identity document, country of issue,
▪ Digital data - videos. These are the data collected through the video surveillance systems used by HRANINVEST Ltd. in all publicly accessible places in each of our hotels (lobby, reception, restaurant, lobby bar, fitness, corridors, stairs, entrances), for security purposes, monitoring, control and protection of public order.
IP address when visiting our website / online booking platform,
▪ Data in connection with a complaint regarding the tourist service provided by us and used by you;
information about the type and content of your reservation, as well as any other information related to it, including e-mails, letters, requests, requests, complaints, grievances and other feedback we receive from you;
2.2. Objectives and legal grounds for the processing of personal data:
Leading basis for processing and storage of 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 before the conclusion of such a contract. At the same time, the processing of certain personal data is necessary to comply with legal obligations of the company under the Tourism Act, the Civil Registration Act, the Accounting Act and other applicable regulations, as well as to protect the legitimate interests of the administrator or a third party. :
A) We process and store personal data that are minimally necessary and legally required for the purposes of providing tourist accommodation and catering services, as well as for all other services provided on site at our hotel such as:
Identification of a client in: making, changing and terminating a reservation, as well as in the provision of tourist accommodation and catering services, as well as all other services provided on site at our hotel. The identification of a client is done through all trade and communication channels - at the reception of 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 Hotel according to your request for correction / change of data / services;
Service and response to customer complaints / inquiries / complaints. Adjustments of amounts due on already realized reservations for accommodation and meals in the presence of grounds for this;
B) In fulfillment of its legal obligations, HRANINVEST Ltd. processes your data for the following purposes:
Providing information to the Ministry of Interior, the competent municipality of the hotel, the Consumer Protection Commission and the Commission for Personal Data Protection, in connection with the implementation of our obligations as a hotelier, arising from current regulations in this area;
processing of your data in invoices issued in your name for other purposes compatible with the original purpose of their collection
Carrying out tax and social security control by the relevant competent state authorities;
Providing information to the court and third parties in court proceedings in order to protect their legitimate interests, including collection of receivables from customers in court;
C) HRANINVEST Ltd. processes your data for the purposes of our following legitimate interests:
for the purposes of direct marketing - sending offers containing information about our current offers, promotions and discounts for accommodation in our hotel and / or change in the conditions of those already used;
to include your name, photos, videos and other data in brochures, website, etc. publications of HRANINVEST Ltd. as a result of your participation in group events and activities organized by us in our hotel (dancing, sports and other entertainment).
to protect, exercise or preserve the legal rights, integrity, safety or property of the administrator, users of the administrator's services and members of the public;
3. Categories of third parties that access and process your personal data: In connection with the implementation of our activities and the fulfillment of our contractual commitments with our customers, we provide your data to the following groups of persons "recipients", namely:
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 representatives in Bulgaria and abroad, transport companies and airlines, suppliers of the relevant basic and additional travel
services, and other subcontractors with whom we have contracts;
payment service providers for online credit card payments
insurance companies when ordering an insurance event with a tourist staying in our hotel;
IT companies supporting information systems, our company website, software and platforms for managing the reservations of our clients, etc .;
to public bodies (Ministry of Interior, municipality, NRA, Consumer Protection Commission, Personal Data Protection Commission, judicial and other control bodies);
Other administrators of personal data to whom HRANINVEST OOD provides your personal data on a legal basis and / or on the basis of a bilaterally signed contract.
It may be necessary - by law, in litigation and / or at the request of public and governmental authorities inside or outside your country of residence, as well as for national security, law enforcement or other matters of public importance, that we disclose your personal information when such disclosure is necessary or appropriate.
We may also disclose information about you if we determine that such disclosure is justified and necessary for the application of our company terms and conditions, or to protect our business, legitimate interests and the rights and legitimate interests of other users. In addition, in the event of a reorganization, merger or sale, it is possible to transfer any and all of the collected database to the relevant successor third party.
4. For how long your personal data is stored. Security:
The duration of storage of your personal data depends on the purposes of processing for which they were collected:
Your personal data processed for the purpose of providing and performing tourist accommodation and catering services in our Hotel are stored for a period of up to 3 (three) years from the date of your departure from the hotel, as well as until the final settlement of all financial relations between the parties, observing the statutory deadlines, when any;
Personal data processed for the purpose of issuing accounting / financial documents for tax and social security control, as well as not only - invoices, debit, credit notices, are stored for at least 3 (three) years, unless applicable law provides longer term.
Picture (Video) - up to 30 days from the creation of the recording.
The storage of personal data for longer periods is possible to protect the legitimate interests of "HRANINVEST" Ltd., as well as until the expiration of the statute of limitations in order to protect any claims of customers in connection with the implementation / termination of tourist accommodation services. and meals in our hotel, 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 Administrator of personal data - "HRANINVEST" Ltd. takes due care and takes the appropriate and required by law administrative, technical and physical measures, as well as those related to staff / training, awareness, etc./ to protect information, with which has, including the protection of 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 regarding protection
of personal data and which we maintain in accordance with modern technological advances.
We are responsible for the protection of personal data of the client, which became known to us in connection with our activities as a hotelier and in providing our travel services specified in the subject of the General Terms and Conditions and this Policy, except in cases of force majeure, event or malicious actions of third parties, as well as in cases where the client has made this information available to third parties.
5. Video surveillance
The common areas of each of our hotels are subject to round-the-clock video surveillance, which is carried out through stationary security cameras located in the respective places.
Video surveillance is carried out in order to protect, exercise or preserve the legal rights, privacy, safety or property of the administrator, his employees and / or contractors, as well as to ensure the safety, privacy and security of hotel guests and members of society.
Video surveillance is organized and controlled by employees of the administrator, specially trained in data protection.
The recordings are stored on video servers for a period of 30 days, except in case of registered violation of the rights of the administrator, tourists or third parties, in which case the term of keeping the recordings may be extended according to specific needs.
You have the right to request a review of the records if you allege an infringement of rights that apply to you or to a person you supervise, and your request will be considered within the time limits set out in section 6 of this policy.
The Company may refuse to consider requests that are unreasonably repeated, require disproportionate technical effort or endanger the privacy of other users.
6. What are your rights in connection with the processing of your personal data by HRANINVEST OOD and what actions should you take to exercise them:
right of access to data relating to him - the client has the right at any time to ask us to confirm whether data relating to him are processed, information on the purposes of such processing, on the categories of data and on the recipients or categories of recipients to which the data are disclosed;
the right to correct and update their personal data when they are inaccurate or incomplete in view of the purposes of their processing;
right of erasure (the right to be "forgotten") when his data are processed illegally or with no grounds for revocation (the original purpose for which they were collected and processed has been fulfilled, expired storage period (including prescription), withdrawn consent for processing, you have objected to their processing, etc.), there is no other reason for processing here either national or European legislation requires it;
right to limit the processing - in the presence of a legal dispute between "HRANINVEST" Ltd. and the individual until its resolution and / or for the establishment, exercise or protection of legal claims; where the processing is unlawful but the data subject does not wish the personal data to be deleted, but instead requests that their use be restricted; in case of an objection made by you against the processing of your personal data for the term of the verification of its validity;
right to data portability - the data subject has the right to ask us to transfer his personal data in machine-readable format to another controller explicitly specified by him without hindrance;
obligation to notify when correcting or deleting personal data or restricting 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 for the cases when this is impossible or is related to excessive efforts for HRANINVEST OOD.
right to report a breach of personal data security - in cases where the breach of data security is likely to pose a high risk to the rights and freedoms of individuals. We are not obliged to inform you if: we have taken appropriate technical and organizational protection measures with regard to the data affected by the security breach, and if we have subsequently taken measures to ensure that the breach does 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 related to the specific situation of the person, provided that there are no convincing legal grounds for the processing, which take precedence over the interests, rights and freedoms of the subject data, or litigation.
When processing personal data for the purposes of direct marketing, the User has the right at any time to object to the processing of personal data relating to him 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 consumer, he shall be explicitly informed of the existence of the right of objection described above, which shall be given to him by notification in a clear manner and separately from any other information.
the right to judicial and administrative protection - the right to lodge a complaint with a supervisory authority, the right to effective judicial protection against a supervisory authority, the right to effective judicial protection against an controller or processor; right to compensation for damages.
Procedure for exercising the rights: You can exercise all your rights regarding the protection of your personal data through the forms attached to this Policy, which you can download here. Of course, these forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data holder.
HRANINVEST OOD considers and decides on 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 of receipt of the application. If necessary, this period can be extended by another 2 / two / months, given the complexity and number of applications. HRANINVEST OOD informs the consumer about any such extension within one month of receiving the application, indicating the reasons for the delay.
Details of the supervisory authority:
COMMISSION FOR PROTECTION OF PERSONAL DATA / CPDP /,
Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., tel .: 02 / 91-53-518, fax: 02 / 91-53-525,
7. Can you refuse to provide personal data to HRANINVEST OOD and what are the consequences?
In order to fulfill the reservation made by you and to provide you with the requested accommodation services in our hotel, we need certain data, which are regulated by the legislation in force in the Republic of Bulgaria.
Failure to provide those specified in item 2.1. personal data prevents the possibility of HRANINVEST Ltd. to accept your reservation and accordingly provide you with the requested services on site at our hotel.
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HRANINVEST OOD has the right, when circumstances so require, to unilaterally update, amend and supplement the personal data protection policy at any time in the future. Any additions or changes to this Policy will be published on the Company's website www.hoteldafi.com and / or will be provided upon request to the client.
This policy was last updated in 2018.