Emsen Designs JSC, entered in the Commercial Register at the Registration Agency with BULSTAT Unified Identification Code (UIC): 202171742, with registered office and management address: Sofia, 32 Atanas Dukov St., 1st floor, is the administrator of personal data at the CPC and processes the provided data and personal information in accordance with the Personal Data Protection Act and the General Data Protection Regulation (EU) 2016/679.

This Privacy Policy applies to Radina‘s Way Hotel and its official website www.radinasway.com.

We, as a personal data administrator and as a professional with many years of experience in the field of tourism, respect the privacy of users. This security policy aims to inform you about the process of collection, use and transfer of personal data. Therefore, please familiarize yourself with its contents by reading it carefully. In case you have any questions, you can ask them at the following e-mail address: gdpr@radinasway.com

DEFINITIONS

In terms of this policy:

Personal data is any information relating to a natural person that is identified or can be identified directly or indirectly by an identification number or by one or more specific characteristics. The data may refer to facts (for example – name, e-mail address, location or date of birth) or to an opinion about the actions or behaviour of the Data Subject.

A personal data administrator is a natural or legal person, public body, agency or other structure that alone or jointly with others determines the purposes and means of personal data processing; where the purposes and means of this processing are determined by Union law or the law of a Member State, the controller or the special criteria for its determination may be established in Union law or in the law of a Member State;

Processing of personal data is any action or set of actions that may be performed in relation to personal data by automatic or other means, such as collection, recording, organization, storage, adaptation or modification, recovery, consultation, use, disclosure by transmission , distribute, provide, update or combine, block, delete or destroy.

Direct marketing is a set of activities aimed at improving the quality of the services we offer and aligning them with the exact needs and interests of our guests, as well as analysing their satisfaction. This includes activities such as: online advertising campaigns, e-mail marketing, surveys, user profiling, etc.

PROCESSING OF PERSONAL DATA

In order to provide and improve the services we provide and for the needs of administering the resources to them, we store, use and process personal data in compliance with the applicable legal requirements.

TYPES OF PERSONAL DATA PROCESSED

The types of personal data that the administrator collects and processes are different, according to the purposes for which they are collected and the grounds for their processing:

The types of data collected according to their purposes are as follows:

1. In order to make a request and confirm a reservation, Emsen Designs JSC collects and processes the following types of data:

a/ When booking, through the website:

– Name and surname of the contact person;

– e-mail address and telephone number of the contact person;

b/ When booking by phone:

– phone number for feedback and e-mail address for confirmation of the reservation

– Name and surname of the contact person;

These data are stored until the reservation is made. After that, the data is destroyed and their subsequent processing is impossible.

2. For the purpose of accommodating guests at Hotel Radina‘s Way, the administrator processes and stores the following data:

– PIN / ID Card;

– Name of the person (for Bulgarian citizens – in Cyrillic, for foreigners – in Latin, according to the national document);

– Date of birth;

– Gender;

– Citizenship;

– ID card number/ valid national identity document;

– Country that issued the national document.

The data collected for the purposes of registration at the hotel are collected on the basis of Art. 116, para. 2 of the Law on Tourism and are necessary for keeping a register of accommodated tourists. The data is stored for a period of 5 /five/ calendar years.

3. For the purposes of holding corporate or personal events, the following data is processed and stored at Hotel Radina‘s Way:

– Two names of the person organizing the event. In case of corporate events, a contact person specified by the legal entity, organizer of the event;

– e-mail address and telephone number of the contact person

These data are stored for up to 3 /three/ calendar years after the realization of the event.

4. For direct marketing purposes, including analyzing and profiling target audiences and to track our customer satisfaction, we process the following data:

– e-mail address

– IP address

– Location

– Language

– Years

– Gender

– Interests

– Behaviour of users of the site www.radinasway.com

The processing and storage of this data requires the express consent of the data subject. Data that is processed for direct marketing purposes is stored for a period of 26 /twenty-six/ months or until consent is withdrawn.

The purpose of collecting this data is to provide you with personalized offers and services that meet your needs and expectations.

Consent form for the use of data provided by you for marketing purposes of Hotel Radina’s Way

PROCESSING PRINCIPLES

When processing personal data, we observe the following principles:

– legality – when collecting, processing and storing your data, we comply with the provisions of the applicable Bulgarian and European legislation;

– good faith and transparency – the data we collect, process and comply with the current privacy policy, which is available to every single user;

– relevance of the processing to the purposes and minimization of the data – the types of data we collect are minimized, in accordance with the purposes for which they are processed. The purposes for which your data is processed are those for which we have obtained your consent;

– storage limitation – we process and store the received data for a period of time, according to the purposes for which they are needed and according to your consent.

– user consent to data processing – in order to use your data for marketing purposes, in order to improve the services, we provide to you, we must obtain your express consent for this.

Please note that when you send an inquiry to Hotel Radina’s Way (for price conditions, for a reservation, for clarification regarding an already made reservation, for holding an event and/or other questions related to the services provided by the hotel) you give your consent to Emsen Designs JSC, to store and process the personal data provided by you for the purposes of the inquiry made.

After sending your inquiry, you will receive from Emsen Designs JSC an offer to give your consent to process your data for the following purposes:

– for direct marketing purposes, as well as to receive newsletters about our current proposed travel ideas and organized games and events;

– for surveys regarding your satisfaction with our services;

By giving your consent to the processing of your data for the purposes of direct marketing, you will not only receive up-to-date information about our most attractive offers, but you will also contribute to the improvement of our services. By giving your consent, we will present you with information about preferential terms and offers, as well as a wide range of products and services, or direct your attention to those that may be of interest to you. This information may contain references to special offers, new products and new services. If you are no longer interested in receiving such information from us, you can opt out at any time by withdrawing your consent to the processing of your data by sending your request to the e-mail address: gdpr@radinasway.com. In this case, your data will be deleted in accordance with the applicable regulations and this privacy policy.

PROTECTION OF PERSONAL DATA

Confidentiality of personal data

We use electronic methods to process personal data in order to ensure accurate and fast provision of services and assistance to users.

The process of processing your personal data provided to EMSEN DESIGNS AD is carried out in accordance with the applicable legislation in the field of personal data protection, and EMSEN DESIGNS AD respects your privacy.

Personalization and cookies

New technologies enable us to customize our website for each individual client. Cookies are text files containing information that allows the identification of returning users. Cookies are stored locally on the device you use to access our website: https://www.radinasway.com and do not cause any damage to your system.

Cookies free you from the need to enter data more than once, facilitate the transmission of specific content and help identify your preferences (view and usability settings). Collecting and analyzing this information allows us to improve the electronic services and the overall user experience so that they meet your needs as closely as possible.

You can familiarize yourself with the cookies and other technologies we use in our Cookies Policy

SECURITY OF PERSONAL DATA

Emsen Designs JSC implements technical and organizational security measures in order to protect the personal data you have provided from accidental or illegal destruction, accidental loss, unauthorized access, modification or distribution, as well as from other illegal forms of processing by unauthorized personas. The security measures we apply are subject to constant improvement and adaptation to the latest technologies.

Collected personal data may be provided to partners of Emsen Designs JSC, who act as personal data processors on behalf of Emsen Designs JSC and have undertaken to comply with all applicable norms for the protection of personal data. We comply with the condition that the relevant information can only be used within the limits set by the legal basis on which it is collected or by your personal consent regarding the processing carried out on behalf of Emsen Designs JSC, and that this information follows to be treated as confidential.

Emsen Designs JSC may disclose and provide personal information in accordance with the applicable law, if a court or administrative body orders or requires this, or if the provision of personal data is related to the fulfilment of a legal obligation of Emsen Designs JSC. The data that is collected for the purposes of accommodation at Hotel Radina’s Way is available to the third parties defined in the Tourism Act – the Ministry of Tourism, the Municipality of Varna and the Minister of the Interior, the National Revenue Agency and the National Statistical Institute.

RIGHTS OF USERS REGARDING THEIR DATA

1. In accordance with current legislation, you have the right to ownership and access to the data you have provided for processing. With a written application to the e-mail address: gdpr@radinasway.com, you can receive information about the type of personal data provided and the purpose of their processing, as well as request that we remove any records of your personal information, without the possibility of further processing. By accessing your data, you can request that it be corrected if you find any errors or inconsistencies.

The written application can be made in person (or by a person authorized by a notarized power of attorney) to the specified contact address or electronically, from the e-mail address you have provided to us as data for processing.

Address for contact and exercise of the rights described above: EMSEN DESIGNS JSC, Address: city of Varna, k.k. “St. St. Constantine and Elena”, administrative building, Email: gdpr@radinasway.com

2. Users have the right to object to the processing of their data. The objection is addressed to Emsen Designs JSC, in accordance with item 1 of this section. Emsen Designs JSC undertakes to consider your objection and, within 30 calendar days of its receipt, to inform you of the result of the internal inspection.

3. Users have the right to appeal to the competent supervisory authority. According to the current regulations, the competent supervisory authority in the Republic of Bulgaria is the Commission for the Protection of Personal Data.

4. Users have the right to receive their data, which Emsen Designs JSC stores, when provided in a structured, widely used and machine-readable format. Users have the right to transfer this data to another personal data controller without hindrance from Emsen Designs JSC, in the cases and in relation to the data provided by consent, in the cases of data provided under a contract to which the user is a party or data provided when the user takes steps and requests to enter into a contract.

CHANGES IN THE RULES FOR THE PROTECTION OF PERSONAL DATA

The rules of EMSEN DESIGNS JSC for the protection of personal data can be changed unilaterally by EMSEN DESIGNS JSC in order to improve them, offer new services, changes in the way of serving and communicating with our customers, as well as in connection with legislative changes.

When making changes to the current rules for the protection of personal data, EMSEN DESIGNS JSC brings to your attention the changes made by publishing them on our website www.radinasway.com, providing you with a reasonable period to familiarize yourself with them, after the expiration of which the same start to apply when processing your personal data, without further notification. If within this period you state that you reject the changes, it will be considered that you have withdrawn your consent to the processing of your personal data and EMSEN DESIGNS JSC will stop processing them for the future. This may also be related to the termination of your registrations for our games, services, electronic newsletters, etc., for the purposes for which you originally provided us with your personal data.

Communication with the Emsen Designs JSC team If you have any questions regarding our measures and rules regarding the protection of personal data, please send a message to the following address with the subject “Emsen Designs JSC – Protection of personal data”: gdpr@radinasway.com