PRINCIPLES FOR PROCESSING PERSONAL DATA

The policy of “ACTIVE DIGITAL ACADEMY” Ltd. aims to ensure compliance with the provisions of the Regulation.

“ACTIVE DIGITAL ACADEMY” Ltd. collects and processes personal data lawfully, fairly and in accordance with the principles and rights of individuals in relation to the processing of their personal data.

“ACTIVE DIGITAL ACADEMY” Ltd.  processes personal data of individuals only in the following cases:

  • processing is necessary for compliance with a legal obligation of “ACTIVE DIGITAL ACADEMY” Ltd.;
  • processing is necessary for the performance of a contract (including an order) with “ACTIVE DIGITAL ACADEMY” Ltd. to which an individual is a party, or to take steps at the request of an individual prior to entering into a contract where his or her identification is required;
  • an individual has given his/her unambiguous consent for an understandable and transparently defined purpose by “ACTIVE DIGITAL ACADEMY” Ltd., for which the processing of his/her personal data is necessary;
  • the processing is necessary to protect the vital interests of the individual whose personal data are processed or of another individual;
  • the processing is necessary for the purposes of the legitimate interests of “ACTIVE DIGITAL ACADEMY” Ltd. or of a third party, in accordance with the provisions of the Regulation;
  • the other cases provided for in the Regulation.

“ACTIVE DIGITAL ACADEMY” Ltd. does not collect or process personal data of individuals that exceed its obligations under the law or its needs for doing business.

In all cases where it is necessary to use collected and processed personal data of individuals for purposes other than the original ones, “”ACTIVE DIGITAL ACADEMY” Ltd. notifies the relevant individuals, requests their consent and proceeds to process their personal data for other purposes only after their explicit consent.

“ACTIVE DIGITAL ACADEMY” Ltd. collects and processes only the minimum necessary personal data of individuals that:

  • are provided for by law;
  • are necessary for the performance of a contract;
  • are necessary for the fulfillment of the purposes for which they are collected.

“ACTIVE DIGITAL ACADEMY” Ltd.  ensures that the processing of personal data of individuals is carried out with maximum accuracy and, if possible, always up-to-date.

“ACTIVE DIGITAL ACADEMY” Ltd ensures that access to and processing of personal data of individuals is carried out by the minimum necessary number of persons (operators) who have the necessary competence for their processing and the necessary commitment to their protection.

STORAGE PERIODS

“ACTIVE DIGITAL ACADEMY” Ltd. stores personal data for the following periods:

  • Data for the register of accommodated tourists within the meaning of Art. 116 of the Tourism Act, which include identification data of the accommodated persons and data related to hotel accommodation – In accordance with the procedure and period provided for in the Tourism Act and the by-laws
  • Information related to requested and used hotel accommodation services, for events and for restaurant services, incl. for canceled hotel accommodation reservations (insofar as they are related to the refund of prepaid amounts and/or withholding of amounts due) – From the making of the relevant reservation/request up to 3 /five/ years from the provision of the service/completion of the contract/cancellation of the reservation. In cases where the services are requested and used on the basis of a contract with continuous performance, the period begins to run from the final performance and/or termination of the contract.
  • Financial and accounting documents; invoices; authorization forms; other information related to tax and social security control – Up to 10 /ten/ years, starting from the beginning of the year following the one in which payment of the obligation for the relevant year is due.
  • Unstructured communication, correspondence, complaints, signals, etc. similar – 5 years.
  • Video data – up to 1 week
  • Data processed based on the explicit consent of the Data Subject – From the moment of granting consent until its withdrawal by the Data Subject.
  • Until a request from the individual for their deletion, when there is a reason for such a request

The personal data specified in this Policy may be processed for a longer period than those specified above, if this is necessary to achieve the goals set forth therein or to protect the rights and/or legitimate interests (including in court) of “ACTIVE DIGITAL ACADEMY” Ltd or if the current legislation provides for the processing of data for a longer period.

In all cases, “ACTIVE DIGITAL ACADEMY” Ltd ensures at least once a year that the collected and processed personal data is reviewed and those of them that fall into any of the above hypotheses are deleted without undue delay.

RULES FOR PROCESSING PERSONAL DATA

  • Personal data is processed with the necessary levels and measures for protection

“ACTIVE DIGITAL ACADEMY” Ltd. ensures the necessary levels of physical, organizational and technological protection in view of:

  • nature the nature, scope, context and purpose of the processed personal data;
  • the likelihood, levels of impact and severity of the risk to the rights and freedoms of individuals in the event of a breach of the security of the processed personal data;
  • its financial and organizational capabilities.

“ACTIVE DIGITAL ACADEMY” Ltd. also provides all necessary measures for the timely recovery of collected and processed personal data in the event of their loss as a result of accidental, malicious or force majeure events.

  • Personal data are processed with controlled and traceable access

“ACTIVE DIGITAL ACADEMY” Ltd. provides the necessary and appropriate technical, organizational and technological measures for controlled and traceable access to the personal data of individuals.

  • Personal data are processed with the necessary accountability for compliance with the Regulation

“ACTIVE DIGITAL ACADEMY” Ltd. provides the necessary accountability and registers to be able to prove that the provisions of the Regulation have been complied with.

DATA SUBJECTS

In connection with the services provided, “ACTIVE DIGITAL ACADEMY” Ltd. processes information about the following Data Subjects:

  • individuals visiting the hotel website;
  • individuals making reservations on their own behalf or on behalf of another individual or legal entity through the Website;
  • individuals using the services provided by “ACTIVE DIGITAL ACADEMY” Ltd., including, but not limited to, hotel accommodation services, restaurant services and related services, provision of premises for organizing other events, as well as individuals representing or otherwise acting on behalf of legal entities using these services;
  • The services of “ACTIVE DIGITAL ACADEMY” Ltd. can only be requested by legally capable individuals who have reached the age of 18.

RIGHTS OF NATURAL PERSONS WHOSE DATA ARE PROCESSED

“ACTIVE DIGITAL ACADEMY” Ltd. ensures compliance with the rights of natural persons whose personal data are collected and processed, which includes:

  • right to be informed about the processing of personal data;
  • right to access personal data – what data is available;
  • right to correct inaccurate personal data;
  • right to delete personal data – the right to “be forgotten”;
  • right to restrict the processing of personal data;
  • right to be informed about actions as a result of a request for correction, deletion or restriction of the processing of personal data;
  • right to data portability;
  • right to object to the processing of personal data;
  • right not to be subject to automated decision-making, including profiling.

PROCESSED PERSONAL DATA

Personal Data Processed in the Capacity of Administrator:

  • of employees;
  • to clients, individuals;
  • to suppliers, individuals;

PURPOSES OF PROCESSING PERSONAL DATA

“”ACTIVE DIGITAL ACADEMY” Ltd.  as the Administrator performs the following operations and processes only the necessary personal data for the following purposes:

  • to conclude, execute and terminate employment contracts and calculate employee salaries and benefits;
  • to accept, administer and process reservations and cancel such;
  • to administer, execute and deliver purchases made through the Website;
  • to administer and receive payments for the services provided, including remotely;
  • to provide services to clients;
  • to ensure an individual approach to the provision of services, consistent with the preferences stated by the users.
  • to conclude and execute contracts with suppliers, individuals;
  • for direct marketing for sales purposes;

RECIPIENTS AND CATEGORIES OF RECIPIENTS

In connection with the implementation of the purposes specified above, “ACTIVE DIGITAL ACADEMY” Ltd. provides personal data of individuals to the following recipients:

  • NRA in connection with the calculation of staff salaries;
  • NSSI in connection with the calculation of staff benefits;
  • Occupational Medicine Company in connection with the obligation to maintain an up-to-date health status of staff and conduct periodic medical examinations;
  • General Labor Inspectorate, NSSI and Ministry of Interior – in connection with occupational accidents;
  • Ministry of Interior – in connection with the transmission of information about hotel guests;
  • Other state and municipal authorities and/or institutions – in connection with legal obligations to them or in connection with legal requests from them for information containing personal data;
  • Subcontractors for the fulfillment of contractual obligations.

VIDEO SURVEILLANCE AND SECURITY

In accordance with the requirements of applicable legislation, “ACTIVE DIGITAL ACADEMY” Ltd.  applies security measures, which include the following technical and organizational means for access control and for ensuring physical security against encroachments on buildings and sites and for protecting the life and health of citizens: a video control system, performing 24-hour video surveillance and consisting of recording and storage devices.

Video surveillance and video recording can be carried out in publicly accessible areas and premises in the buildings of “ACTIVE DIGITAL ACADEMY” Ltd. and in those for which a special access regime is provided. Video surveillance is not carried out in guest rooms, sanitary and hygienic premises, recreation rooms, etc. Data from video surveillance activities are stored for a period of seven days.

Through information boards placed in a prominent place, Data Subjects and other visitors who may be filmed are notified of the use of technical means of surveillance and control and of any other relevant information in connection with the surveillance.

Processing of personal data for marketing purposes

Categories of personal data.

The processed personal data may include:

  • Name and surname
  • email
  • telephone

Legal basis for processing

The processing of personal data for marketing purposes is carried out on the basis of your explicit consent. You have the right to withdraw your consent at any time by contacting us or using the unsubscribe option provided in each marketing message.

Data retention period Personal data will be stored until the which you withdraw your consent or until the expiration of the legally specified period.

Your rights You have the right to access, rectify, erase, restrict processing and object to the processing of your personal data, as well as the right to data portability. For more information, please contact us.

COMPANY CONTACT DETAILS

If you have any questions or concerns regarding the processing of your personal data or wish to exercise any of your rights, you can contact:

  • e-mail: hotel@hotelzlatenrozhen.com
  • telephone: 0879 801 300
  • address: Sofia 1164, Lozenets district, 23 Hristo Smirnenski blvd.

COMPETENT SUPERVISORY AUTHORITY

On the territory of the Republic of Bulgaria, the competent supervisory authority is the Personal Data Protection Commission.

In case of doubt that your rights related to the protection of your personal data have been violated, you can file a report to:

  • Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
  • Email: kzld@cpdp.bg
  • Phone: 0879 801 300