Dear customers and partners,
For us, the protection of personal data is an important issue and therefore we have taken the necessary measures to provide you with summary information about the processing and protection of personal data by
“ASPITUR” Ltd., as part of ASPIGROUP. I have the responsibility to perform the functions of personal data protection in the company “ASPITUR” Ltd., part of ASPI GROUP, and I believe that the information provided will help you find answers to all questions related to your personal data. You can contact my team on all matters related to the processing of personal data and the observance of your rights. In the provided information you will find answers to frequently asked questions, explanations of concepts related to personal data protection, and other useful information related to the processing of your personal data. Who can contact the Data Protection Officer? The personal data protection officer is appointed in accordance with the provisions of Art. 37 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 repealing Directive 95/46 / EC ( General Regulation on Data Protection) in the company “ASPITUR” Ltd., part of ASPI GROUP. The duties of the Data Protection Officer include the obligation to protect the rights and interests of data subjects. All personal data subjects may apply to the Data Protection Officer. The subject of personal data is any person to whom the personal data relate.These are all citizens of the European Union (EU) whose rights are protected by the General Data Protection Regulation. The protection of personal data only applies to living persons, as the General Rules exclude data on deceased persons from their scope. In view of the activity of “ASPITUR” Ltd., part of ASPIGROUP, these are primarily our customers, employees and business partners. The Personal Data Protection Officer is responsible for compliance with the requirements regarding the application of the rights of data subjects in the company “ASPITUR” Ltd., part of ASPIGROUP. What are the responsibilities of the Data Protection Officer? The Data Protection Officer organizes communication and assistance to subjects in cases where their rights to the processing of their personal data have been violated and, in the case of the exercise of their rights, in accordance with Regulation 2016/679 (General Regulation on Personal Data Protection). These are the following basic rights:• right of access to personal data;• right to correction of personal data;• right to receive information about the processing of personal data;• the right to restrict the processing of personal data;• right to portability of personal data;• the right to object to the processing of personal data; right to refuse automated data processing, including profiling; • right to be erased (right to be forgotten);• the right to receive information in case of breaches related to the security of personal data;• the right to withdraw consent for the processing of personal data; Each of these rights can be exercised by the entity by submitting an application. Submission of an application in connection with personal data You can submit your application to the Data Protection Officer. Your applications will be considered as soon as possible. The person who accepts your application (the controller or the data protection officer) will provide you with information on the measures taken within one month of receiving your accurate and comprehensible application, provided that the applicant is uniquely identified. That period may be extended by a further two months if this is necessary due to the complexity of the case and the number of applications. The controller (personal data protection officer) is obliged to inform you of any possible extension within one month of receiving the application, stating the reasons for such postponement. If your application cannot be identified or is not worded accurately and understandably, the controller or data protection officer will contact you to request that it be supplemented, from which time the one-month period for reviewing your application ceases to run- until the day of its completion. In this regard, please note that if you do not complete your application within a reasonable time, it will not be considered and will be rejected on the basis of Article 12 of the Regulation. Applications may be submitted in one of the following ways: • In person at the reception of Aparthotel BENDITA MARE,• By mail;• By e-mail. The answer will be sent to you in the manner specified in the application. If the administrator is unable to take the measures you have requested, you will also be informed no later than one month after receiving your application. The provision of the requested information by us, as well as the satisfaction of your requests is free of charge. In the case of applications that are unjustified or unreasonable, mainly because they are repeated, the administrator has the right to:(a) require an appropriate fee, including administrative costs, incurred in connection with the provision of the requested information or communication or in connection with the action taken;or(b) reject the application. How to contact the Data Protection Officer: • Address: Varna, Golden Sands, Apart-hotel BENDITA MARE Website: www.benditamare.eu• Phone: 0887757510• The administrators appoint as a data protection officer: VALENTIN NANUSHEV• E-mail: Managerbendita_aspigroup@abv.bgEnclosed we give you the opportunity to get acquainted with our PRIVACY POLICY
PERSONAL DATA PROTECTION POLICY of BENDITA MARE APART–HOTEL This Policy aims to ensure that employees, contractors and customers of Aparthotel BENDITA MARE (the “Organization”), in their capacity as Data Administrator, are informed of their personal data processed by the Organization, as well as to ensure the lawful , diligent and transparent processing of personal data. Personal data is any information related to an individual that may directly or indirectly lead to his / her identification. Such information may be name, date of birth, PIN, address, ID number, telephone number, e-mail address, health status, online identifiers, electronic communication data, etc. The general policy for personal data protection of Apart-hotel BENDITA MAREand the Data Protection Policies (the “Policies”) and the Procedures for the Processing of Personal Data in Individual Processing Hypotheses (the “Procedures”) are designed to guarantee the rights of individuals with regard to the protection of their personal data when processed by the Organization. The general policy for personal data protection of Apart-hotel BENDITA MAREcontains the basic rules and provides information on:
1. Purposes of personal data processing;
2. Means for collecting and means for processing personal data;
3. Disclosure of personal data
4. Access to personal data, modification, correction, restriction of processing and deletion of the same; right to appeal to supervisory authorities;
5. Protection of personal data;
6. Use of personal data of children;
7. Transfer of personal data;
8. How to contact the Organization;
9. Terms for processing and storage;
10. In case you do not provide your personal information;
11. Update and change of the current General Policy for Personal Data Protection, as well as its current version.
BENDITA MARE Apart-hotel collects and uses your personal data only for the purposes specified in this Policy. 1. Purposes of personal data processing 1.1 Purposes of processing the personal data of the clients Apart-hotel BENDITA MAREApart-hotel BENDITA MARE processes personal data in order to offer goods and services to its potential guests. In this connection Apart-hotel BENDITA MARE may process the data related to names, PIN, Ident. №, addresses and / or e-mail addresses, etc.,• Apart-hotel BENDITA MARE processes personal data about its guests for the purposes of the contract / contracts concluded between Aparthotel BENDITA MARE and the travel or tour operator agency, including for accounting purposes in connection with the legal obligations of the administrator. For this purpose, the data of the person that can be processed are the following: name, personal identity document or date of birth, identification number, address, e-mail, telephone number, etc.• Apart-hotel BENDITA MARE processes the following personal data with the explicit consent of the individual for the purposes of marketing research and delivery of additional goods and services to its guests: name, e-mail address, telephone number, technical details of the device and others .• Apart-hotel BENDITA MARE processes the personal data of its guests in order to realize their legitimate interests, including in connection with the implementation of a specific contract with a tour operator, including for the purposes of debt collection and obligations of the administrator arising from a legal act or ordered by a competent authority. For this purpose, the Organization processes names, PIN, identification number, contract number / customer number, address, telephone number, e-mail address, etc.• Processing of personal data: Apart-hotel BENDITA MARE may entrust a third party to process personal data outside the structure of the controller, which provides sufficient guarantees to meet the requirements of the relevant legal framework in the field of personal data protection. The personal data processing activities that the Organization may entrust with the processing of personal data are, for example: accounting and legal services, security and video surveillance, construction, supply and maintenance of software products, computer systems, websites, including to assign debt collection; by selling the receivable, through assignment agreement. In this regard, it must provide the relevant party to the assignment agreement with the data of the natural person. 1.2 Purposes of the processing of personal data of partners by Apart-hotel BENDITA MARE administrators or processors of personal data. • Apar-thotel BENDITA MARE processes personal data of its potential contractors, representing administrators or processors of personal data in order to establish contractual relations, offer goods and services, outsource activities or take action on behalf of its potential partners, with a clear intention to enter into a contract. In connection with this, Apart-Hotel BENDITA MARE may process data that personalize the person or his / her representatives, for example: names, telephone numbers, addresses and / or e-mail addresses, etc.• Apart-hotel BENDITA MARE processes personal data of its contractors for the purposes of performing a contract (s) concluded between Aparthotel BENDITA MARE and the contractor, including for accounting purposes, in connection with the legal obligations of an administrator. For this purpose, data of an individual can be processed, such as name, personal identity document or date of birth, identification number, address, e-mail, telephone number, etc.• Apart-hotel BENDITA MARE processes personal data with the explicit consent of the individual for the purposes of marketing research and providing additional goods and services to its colleagues: name, e-mail address, telephone number, technical details of the person’s devices and more.• Apart-hotel BENDITA MARE processes the personal data of its counterparties for the purposes of fulfilling its legitimate interests, including in connection with the performance of a specific contract, including for the purposes of debt collection, as well as obligations of the administrator arising from a legal act or ordered by a competent authority. For this purpose, the Organization processes names, PIN, identification number, contract number / customer number, address, telephone number, e-mail address, etc.• For the purposes of Art. 2.2 of the General Privacy Policy, Apart-hotel BENDITA MARE may process personal data of employees of its contractors or assign the same to the processing of personal data of its employees, and the contracting party must provide sufficient guarantees of information and valid consent of the employees.• Processing of personal data: Aparthotel BENDITA MARE may entrust a third party to process personal data outside the structure of the controller, which provides sufficient guarantees to meet the requirements of the relevant legal framework in the field of personal data protection. The personal data processing activities that the Organization may entrust with the processing of personal data, are for example: accounting and legal services, security and video surveillance, construction, supply and maintenance of software products, computer systems, websites, including to assign collection of receivables; by selling the receivable, through assignment agreement. In this regard, it must provide the relevant party to the assignment agreement with the data of the natural person. 1.3. Purposes of processing the personal data of the employees employed under civil law relations with Apart-hotel BENDITA MARE • Apart-hotel BENDITA MARE processes personal data of its potential employees, respectively individuals engaged in civil relations, for the purposes of recruitment and announcing and conducting a job vacancy, as well as the application of the individual for employment at the administrator, with a clear intention to enter into a contract. In this regard, Apart-Hotel BENDITA MARE may process data individualizing the individual, such as: name, telephone, address and / or e-mail address, work and professional experience, information on acquired educational qualifications, etc.• Apart-hotel BENDITA MARE processes personal data of its employees, respectively individuals employed under civil contracts for the purposes of labor, social and health insurance legislation, including the keeping of employment records, the employment of employees, as well as the payment of remuneration and benefits for temporary incapacity for work and incapacity for work. In addition, for the purposes of performance of concluded contracts, including accounting purposes, in connection with the legal obligations of the administrator, the amendment, continuation and termination of the legal relationship. For this purpose, the following data of individuals can be processed: name, PIN or date of birth, ID number, address, e-mail, telephone number, etc.• Apart-hotel BENDITA MARE processes the personal data of its employees, respectively individuals engaged in civil relations, in order to realize their legitimate interests, including in connection with the implementation of a specific contract, including obligations of the administrator arising from a regulation or order from competent authority. For this purpose, the administrator processes name, PIN, identification number, contract number, address, telephone number, e-mail address, etc.• Processing of personal data: Apart-hotel BENDITA MARE may entrust a third party to process personal data outside the structure of the controller, which provides sufficient guarantees to comply with the requirements of the relevant legal framework in the field of personal data protection. Personal data processing activities, which the Organization may assign to the processing of personal data are, for example: accounting and legal services, security and video surveillance, construction, delivery and maintenance of software products, computer systems, websites, etc. 2. Means for collecting and processing personal data Apart-hotel BENDITA MARE collects your personal data in the ways specified in this Policy 2.1. The personal data of our potential and actual guests, contractors, employees / employees and persons employed under civil law relations may be obtained or collected directly from the person to whom they relate; by another person for whom Apart-Hotel BENDITA MARE its representative or authorized person will notify the data subject; by a body or institution, subject to a valid legal basis for obtaining the data. With a clear intention to enter into a contract or to pursue the legitimate interests of the controller, we may also obtain your personal data through access to public registers.2.2. Personal data and information about the individual can be submitted to us in the form of documents, forms, letterheads, applications, letters and correspondence. Your personal data can then be processed during your visit to our hotel, which has an access control system and / or a video surveillance system.2.3. We may collect or receive your personal information from our own websites or the websites of our partners (including cookies) in accordance with the terms of this Policy, from the devices, pages and brands you use on social networks and from other sources, as well as from other sources, provided that there is a valid legal basis for this and compliance with the rules on personal data protection.Apart-hotel BENDITA MARE processes your personal data with the means specified in this Policy.2.4. Non-automated means of personal data processing. Such are all means by which the decision to process personal data or to carry out a particular processing activity involves human intervention. In a non-automated way and with non-automated means we process the received documents on paper and electronic media, including contracts, written or oral correspondence, statements of the data subjects, etc. This type of data processing is performed on both paper and other physical media and in an electronic environment, using computer systems and configurations, multifunction devices such as printers, scanners, copiers and fax machines, as well as using specialized software as accounting software. 2.5. Automated means for personal data processing. These are all means by which the decision to process personal data or to perform a certain action on the processing of personal data is made in the absence of human intervention. Our organization does not typically use fully automated means to process personal data. However, for this type of processing, it is possible to accept, for example, the receipt of information using cookies. 3. Disclosure of personal data Apart-hotel BENDITA MARE will disclose, including by providing, your personal data only in the cases specified in this Policy. 3.1. In the presence of a legal obligation or at the discretion of a competent authority or institution, the controller will disclose and / or provide your personal data to the relevant authority or institution or to another person.3.2. After providing your explicit consent, when concluding or negotiating a contract with Apart-hotel BENDITA MARE.3.3. In case of an advantage for the administrator arising from a legal provision or other valid legal basis. Also in situations where the life, health, fundamental rights and freedoms of the data subject, third party and / or group of persons, as well as public health and security of public order, are endangered. 4. Ensuring access to personal data, change, correction, restriction and deletion of the same, right to appeal to a supervisory authority 4.1. You have the right to request and receive from Aparthotel BENDITA MARE confirmation that the personal data related to you are processed by the administrator.4.2. You have the right to access data and information related to the collection, processing and storage of your personal data by the administrator.4.3. You have the right to receive information about the logic of the processing of your personal data, the purposes and time of processing and storage of data, information about the categories of recipients to whom your personal data may or have been disclosed or provided for processing on behalf of the administrator.4.4. If you do not want all or some of your personal data to continue to be processed and / or stored by Apart-Hotel BENDITA MARE in case the administrator has no obligation to continue to process and / or store the data or there is no overriding legitimate interest of the administrator to continue the processing and / or storage of personal data, you may object to the processing or request to limit or terminate the same and delete your data. This objection, respectively, may be made in respect of all or some of the processing hypotheses, both for the full amount of personal data and for some of them.4.5. You have the right to ask the administrator to update, correct or supplement your processed personal data.4.6. You can request the deletion, restriction of processing or return of your personal data, and the administrator will be obliged to fulfill your request in case:• personal data are no longer needed for the purposes for which they were collected or otherwise processed;• You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;• Your personal data is processed illegally;• Your personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to Apart-hotel BENDITA MARE.4.7. The administrator is not obliged to delete, restrict the processing or return your personal data, in cases when it stores and processes them:• for the exercise of the right to freedom of expression and the right to information;• to comply with a legal obligation requiring treatment provided for in EU law or in the law of the Member State applicable to the controller, or in the performance of a task in the public interest or in the exercise of official authority conferred on him;• for reasons of public interest in the field of public health;• for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;• to establish, exercise or defend legal claims;• to exercise the rights of data controllers, which take precedence over the legal interest of the natural person.4.8. In order to exercise the above rights, you must submit a written request to Apart-Hotel BENDITA MARE, proving your identity and describing exactly the basis of your request, to which categories of personal data your request relates, and about which actions for processing and storing your personal data, you submit request. The request according to the previous sentence can be addressed either in writing to our employee in an office or to the office of the administrator, or electronically, in compliance with the requirements of the Electronic Document and Electronic Signature Act.4.9. You have the right to file a complaint for violation of your rights regarding the protection of your personal data to the Commission for Personal Data Protection, address: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2 (www.cpdp.bg) 5. Protection of personal data 5.1.In accordance with the requirements of the General Data Protection Act and the relevant regulations in the field of personal data protection, Apart-Hotel BENDITA MARE regularly performs audits and analyzes of its activities, as well as risk and impact assessment for personal data, the protection of personal data and the legal sphere of data subjects.5.2. In this regard, Apart-Hotel BENDITA MARE introduces and maintains in its organization an adequate level of security and protection of personal data through the application of appropriate technical and organizational measures for protection of personal data and information security.5.3. Apart-hotel Apart-hotel BENDITA MARE conducts regular briefings and trainings for its employees in order to raise their awareness of their rights and obligations in connection with the processing of personal data, as well as the development of the legal framework and technical progress. 6. Use of children’s personal data 6.1.Apart-hotel BENDITA MARE does not collect and process personal data of children intentionally for purposes other than the purposes of labor and social security legislation, as far as the employees of the administrator are concerned. In these cases, the employee consents to the processing.6.2. Aparthotel BENDITA MARE collects and processes personal data of children and the same can happen when visiting the administrator, where there is a video surveillance system. In such cases, the rules and requirements of the General Data Protection Regulation and the relevant legal framework in the field of personal data protection shall be complied with. 7. Transfer of personal data 7.1. Apart-hotel BENDITA MARE usually does not transfer personal data outside the Republic of Bulgaria.7.2. Apart-hotel BENDITA MARE may provide your personal information to the relevant travel or tour operator agency through which you requested the use of our services in case of contractual or legal liability of the administrator or in order to realize the overriding interest of the Organization, and also when is required to exercise your rights.7.3. The administrator may provide your personal data to an insurance company outside the Republic of Bulgaria in case of insurance taking or for exercising other rights of yours or in view of legal obligations or preferential interests of the administrator. 8. How to contact the Organization How to contact the Data Protection Officer: • Address: Varna, Golden Sands, Apart-hotel BENDITA MARE Website: www.benditamare.eu• Phone: 0887757510• The administrators appoint as a data protection officer: VALENTIN NANUSHEV• E-mail: Managerbendita_aspigroup@abv.bg 9. Terms for processing and storage Apart-hotel BENDITA MARE processes and stores your personal data within the terms specified in this General Data Protection Policy or the conditions agreed between the parties to the contract or upon granting consent for data processing.9.1. Apart-hotel BENDITA MARE processes and stores your personal data for periods not longer than strictly necessary to achieve the purposes of processing your personal data;9.2. The administrator processes personal data within the statutory time limits, when such data exist.9.3. The time limits for the processing and storage of personal data may also be set between the parties to the contract with the data controllers, in accordance with the purposes of the data processing and the requirements of the relevant legal framework. 10. In case you do not provide us with the necessary personal data according to the purpose of processing due to the need and / or obligation of Apart-Hotel BENDITA MARE to process them, we cannot enter into a contract with you and / or provide you with the desired goods or services. 11. Update and change of the current General Policy for Personal Data Protection, as well as the current version.11.1. All future changes to the General Privacy Policy will be published on the website of Aparthotel BENDITA MARE11.2. Depending on the possibilities for contact with individuals and the nature of the relationship between the controller, changes in the General Policy for Personal Data Protection, as well as the creation and updating of individual policies for personal data processing will be notified to data subjects in a timely manner.