Privacy policy

NOTICE OF CONFIDENTIAL TREATMENT OF PERSONAL DATA

STENATA PROPERTY MANAGEMENT Ltd. entered in the Commercial Register at the Registry Agency with UIC 204706065 is a personal data administrator (PCA) within the meaning of Regulation (EU) 2016/679 and other applicable acts of the European Union and the Republic of Bulgaria.

The purpose of this communication is, in accordance with the information requirements under Art. 13 and Art. 14 of the ORD, to inform you about the personal data processing activities performed by “STENATA PROPERTY MANAGEMENT” Ltd. as a data controller, the purposes for which the data are processed, the measures and guarantees for the protection of the processed data, your rights and the way in which you can to practice them.

For all questions related to the processing of your personal data, you can contact the data protection officer of “STENA PROPERTY MANAGEMENT” Ltd. by e-mail: dpo@marinahotels.bg, and in your message you should specify the necessary data for your individualization and contact for feedback.

You can also contact us at our management address: Varna, 21 Maria Luiza Blvd., apt. office 2.

What personal data do we collect, for what purposes and on what legal basis do we process it?

As PDA “STENATA PROPERTY MANAGEMENT” Ltd. collects personal data for specific, precisely defined by law purposes and processes them lawfully and in good faith.

In carrying out its activities, the PDA processes personal data of individuals for the following purposes:

For the purposes of his lawful (legitimate) interest;
Fulfillment of obligations under a contract or to take steps at the request of the client before concluding a contract;
Compliance with a legal obligation that applies to the company;
Explicit consent received from you as a customer;

The reasons that give us the right to process your data are described in detail in the Tourism Act, the Civil Registration Act (mandatory hotel registration in the place where you will stay), the Electronic Document and Electronic Certification Services Act (when paying through POS terminals) and other relevant regulations.

In carrying out its activities, the company processes personal data of individuals to perform the contracts it concludes. In connection with their implementation, the data controller collects and processes personal data of individuals, limited to what is necessary, sufficient for the accurate performance of the obligations under the contract. Access to this information is granted to third parties only when specified in a special law.

To fulfill its obligations under a contract, the company sometimes processes data of children under 18 years of age, which are provided by their legal representatives – a party to a contract with us. The data of the children at the hotel accommodation are necessary insofar as they are required by regulatory requirements.

When we process personal data on the basis of the subject’s consent, the data are only processed if the persons have freely, specifically, informedly and unambiguously expressed their consent to the processing.

Video surveillance is carried out at our sites in order to protect, exercise or preserve the legal rights, inviolability, 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 the public. Video surveillance recordings are stored for a period of one month. Certain employees have access to the data within the framework of their official duties. The purpose of personal data collection is to identify individuals in order to control access.

STENA PROPERTY MANAGEMENT Ltd. processes your data only for the purposes for which it was collected and does not use it for other purposes. These goals are entirely related to the use of tourist services offered by the company.

As PDA “STENA PROPERTY MANAGEMENT” Ltd. stores your personal data on paper and technical media and applies the necessary technical and organizational measures to ensure an appropriate level of security, including protection against unauthorized access, accidental loss, destruction or damage.

According to the purposes, different types of personal data are collected:

1. For requesting or confirming a reservation, STENA PROPERTY MANAGEMENT Ltd. collects the following types of data:

When booking, through the website – Name and surname of the contact person; e-mail address of the contact person;
When booking by phone – phone for feedback and e-mail address to confirm the reservation; Name and surname of the contact person.

This data is stored until the reservation is made. Then the data is destroyed and their further processing is impossible.

2. When accommodating guests, as an administrator we process and store the following data:

PIN / LNC;
Name of the person (data are written according to the national document);
Date of birth;
Gender;
Citizenship;
Identity card number / valid national identity document;
А country that issued the national document.

Pursuant to Article 116, paragraph 2 of the Law for Tourism, the data in the kept register for accommodated tourists are stored for a period of five calendar years.

3. For realization of corporate or personal events the following data are processed and stored by the PDA:

Two names of the person-organizer of the event. In case of corporate events – contact person, indicated by the legal entity, organizer of the event;
E-mail address and contact phone number of the contact person.

These data are stored for a period of up to three calendar years after the event.

Transfer of personal data to a non-EU country or to an international organization?

The company does not provide personal data to third parties outside the EU or to an international organization without first obtaining your consent.

How long do we store your personal data?

As PDA “STENATA PROPERTY MANAGEMENT” Ltd. stores your personal data for a period not longer than the requirements of the applicable legislation for the relevant period.

What are your rights?

As a PDA, we have taken measures to protect your personal data in accordance with the requirements of Regulation 2016/679, which are aimed at ensuring the rights of the subjects whose personal data are processed, namely:

– Right of access;

– Right to correct inaccurate or incomplete data;

– Right of deletion (the right to be forgotten), if the conditions of art. 17 of REGULATION 2016/679;

– Right to limit processing;

– Right to data portability, if the conditions for portability under Art. 20 of REGULATION 2016/679;

– Right to object, if the conditions of art. 21 of REGULATION 2016/679.

– The right of the data subject not to be the subject of a decision based solely on automated processing involving profiling.

How can you enforce your rights?

You can exercise the above rights by submitting a written application (in person or through an explicitly authorized person through a notarized power of attorney) to the personal data controller (“STENA PROPERTY MANAGEMENT” Ltd.), in which you should specify your request. The request should be signed and sent to the address of the PDA. The application may also be submitted electronically in accordance with the Electronic Document and Electronic Signature Act.

You have the right to appeal to the supervisory authority

You have the right to file a complaint to the supervisory authority, the competent authority being the Commission for Personal Data Protection, address: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2 (https://www.cpdp.bg/).

In case you wish to file a complaint regarding the processing of your personal data through the PDA (recipients, including outside the EU and international organizations), you can do so at the specified contact details of the company or directly to the Data Protection Officer.