01

What information we collect

Information you provide to us

When you make a reservation through the website or use our services, we collect personal data about you, including your name and contact details, which are the minimum details required to make a reservation, postal address, billing address, information about your stay, nationality, identity-document details without making a copy, such as the document number, date and place of issue, permanent address, history of previous stays and payment information, such as your bank account details. You may also choose to provide preferences and special requirements. If you share sensitive personal data, such as information about your health, we will process it to provide the requested services and meet your specific needs. We also process information that you provide in connection with a claim, complaint or compliment for the period necessary to respond to it. When you use additional services at our properties outside hotel accommodation, we process the data required by us or by the relevant service providers to provide those services. In limited circumstances, we collect personal data about accompanying guests under the age of 18 where this is necessary to complete the legally required accommodation registration cards. The information is the same as that collected for adults, except that we do not collect contact details, banking details or other financial information. We use video surveillance at our properties to protect the security of our guests and their belongings. We do not use identification technologies or collect biometric data, such as facial-recognition data. Areas under video surveillance are clearly marked with appropriate signs.

Information we collect automatically

When you use the website, we also collect information from your device, including your computer, phone or tablet. This may include your IP address, browser and language settings. In most cases, this information is anonymous and does not allow us to identify you. For information about cookies, please read our Cookie Policy.

Information from other sources

We may also receive information about you from other sources, including our partners, such as payment-service providers, independent third parties, including Booking.com and other booking platforms when you make a reservation through them, travel agencies and tour operators. This information may be combined with the information you provide to us and used for the purposes described in this Policy. If you attend an event organised at one of our properties by a third party, we may receive and process your information to provide access to or participation in the event, where this is required by the organisers or where another valid legal basis for processing applies.

02

Why we collect your data and the legal basis for processing

We use your personal data for several purposes:

• To process your online reservation.
• To provide the services included in your reservation and arrange your stay.
• To communicate with you regarding your reservation or stay.
• To maintain our statutory records, including the register of accommodated tourists that we are required to maintain under the Bulgarian Tourism Act.
• To provide a service tailored to your needs and preferences.
• To respond to your requests and complaints.
• To protect your safety and our property at our premises.
• For statistical purposes.
• For direct marketing.

The legal grounds on which we collect and process your data are compliance with our legal obligations under item 4, performance of our contract with you under items 1 and 2, protection of our legitimate interests under items 3, 5, 6 and 8 or, where applicable, your prior consent under item 9. When we process your data on the basis of our legitimate interests, you have the right to object to that processing by contacting us at the email or postal address provided at the end of this Policy.

03

How long we retain your data

We retain your personal data only for the minimum period necessary to fulfil the purposes described in this Policy, unless we are legally required or otherwise entitled to retain it for a longer period. We determine the retention period by considering several factors, including the duration of the services provided, such as whether the price of your stay was paid upon departure, the need to establish, exercise or defend legal claims, and any statutory retention obligations, such as the requirement to retain accounting documents for five or ten years.

04

Who we share your data with

We disclose your data only to trusted partners where this is necessary for the services we use, such as web-design and website-maintenance providers, and only after ensuring that they comply with high standards of information security and confidentiality. This is necessary to improve the operation of our website. Other third parties that may receive some of your data include parties that assist us in providing our services, such as financial institutions, advertisers or, in certain cases, public authorities, including when we submit the mandatory register of accommodated tourists to the Bulgarian Ministry of Interior. We will never sell your information to third parties or use it for purposes about which you have not been informed and to which you have not given prior consent. We will not transfer your data to countries outside the European Union.

05

How we protect your rights

We process your personal data only in accordance with the purposes, legal grounds and retention periods specified in this Policy. When collecting data, we collect only the minimum amount required and only for clearly defined purposes and predetermined retention periods. Access to the data is restricted to a limited number of individuals who have been appropriately trained and instructed in how to handle it.

06

What your rights are

As a data subject, you have the right to receive confirmation and/or detailed information about the processing of your personal data, including a copy of the personal data that we process about you. This is known as the right of access. You may object to the collection and further processing of your data and request that it be corrected or updated, or deleted where there is no valid legal basis for us to continue processing it. You may withdraw your consent to the processing of personal data at any time by using the Consent Withdrawal Form. If you believe that your data-protection rights have been infringed, you have the right to submit a complaint to the Bulgarian Commission for Personal Data Protection. For questions about your rights or to exercise any of them, contact us at privacy@thracian-hoteliers.com or by post at: 27 Ring Road Street, 1404 Sofia, Bulgaria.

07

Contact us