Policy GDPR

PERSONAL DATA (GDPR)
PRIVACY POLICY AND PROTECTION OF PERSONAL DATA
 
We, at “BUSINESS CLUB – VALENTINA PETROVA” EOOD are aware of the importance of protecting the personal data of our clients and partners, as we strive to maintain good policies and practices that provide the utmost protection of your personal data processed in and / or in connection with the provision of basic and / or additional tourist services for accommodation and food, as well as other services offered on-site at the hotel, managed by us.  
This Privacy Policy is based on the requirements of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of individuals in regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“Regulation (EU) 2016/679”).  
All changes and additions in the Privacy Policy will be applied after the publication of its current content, accessible via our website www.vpbusiness.club.  The Privacy Policy applies to your personal data, if you are an individual or a representative of a legal entity, which is using or would want to use the services, offered in hotel the managed by the company “BUSINESS CLUB-VALENTINA PETROVA” EOOD, including those, offered online through a specialized platform on our website, including via social networks.  
  1. Who processes and is responsible for your personal data:
“Business Club – Valentina Petrova” EOOD (“we”) is the company registered in the Commercial Register at the Registry Agency with UIC 206106891, which collects, processes and stores your personal data under the terms of this Policy and the applicable legislation of the European Union and the Republic of Bulgaria.
“BUSINES CLUB – VALENTINA PETROVA” EOOD is an administrator of personal data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of individuals in regard to the processing of personal data and on the free movement of such data and the Personal Data Protection Act.
For all questions, related to the processing of your personal data, you can contact us at our address of management: Shumen, Hristo Smirnenski Str. 2
Or at the following contact details:
www.vpbusiness.club.contacts / or gdpr@vpbusiness.club
2. What data, for what purposes and on what legal basis we process:
2.1 Depending on the specific purposes and grounds “BUSINESS CLUB – VALENTINA PETROVA” EOOD processes the below mentioned data alone or in combination with each other, namely:
A) Data provided by you, necessary for identification and execution of reservations made by you and confirmed for our Hotel, such as:
- three names, telephone number and/or the email address for contact with you, or a contact person specified by you, date and time of accommodation and departure, children and their age;   
- data, gathered upon payment, made to us - credit or debit card number, bank account and other information, collected during and processed in connection with the payment by bank transfer, by direct debit or through the POS-terminal of "BUSINESS CLUB - VALENTINA PETROVA EOOD;
- data from your account to access our online booking platform – user name, history of reservations and payments;  
- data about the services you use and the information obtained through them about your preferred destinations, hotels and services, offered by us; 
- other data, that you provide to us in connection with the services already used or your preferences for our hotel.
B) Data provided by you and stored by "BUSINESS CLUB - VALENTINA PETROVA"EOOD in the process of providing accommodation services on site at the hotel, which data is collected, processed and stored according to the current regulatory requirements, regarding the keeping of a register of accommodated tourists by the individuals, which are operating a hotel business, namely:
- Names of the individual; EGN / for Bulgarian citizens / or LNC / for foreign citizens with a residence permit in BG /, or date of birth / in all other cases /, gender, nationality; ID card number / valid national identity document, country of issue of the national document.
C) Other:
- Digital data – video recordings. Those are the data, collected by the the video surveillance systems used by BUSINESS CLUB - VALENTINA PETROVA EOOD in all publicly accessible places in our hotel (lobby, reception, restaurant, corridors, stairs, entrances), for the purpose of security, surveillance, control and protection of public order.
- IP address when visiting our website/our platform for online reservations,
- Data in connection with a complaint regarding a tourist service provided by us and used by you;
- Information regarding the type and content of your reservation, as well as any other information related to it, including e-mail, letters, demands, requests, complaints, grievances and other feedback that we receive from you;
2.2 Objectives and legal grounds for processing personal data:
The leading ground for processing and storage of personal data is the performance of a contract to which the data subject is a party or for taking steps at the request of the data subject before the conclusion of such a contract. At the same time, the processing of certain personal data is necessary to comply with the company's legal obligations under the Tourism Act, the Civil Registration Act, the Accounting Act and other applicable regulations, as well as to protect the legitimate interests of the administrator or a third party, as:
  1. We process and store personal data, which are minimally necessary and legally required for the purposes of providing tourist accommodation and food services, as well as for all other services provided on site in our hotels such as:
  • Identifying a client during: making, changing and terminating a reservation, as well as the provision of tourist accommodation and food services, as well as all other services provided on site at our hotel. The identification of a client is done through all commercial and communication channels - at the reception in the Hotel by providing an identity document, by phone, on our online platform through an electronic contact form, by e-mail, etc.;
  • Updating of your personal data or information about services in our Hotel according to your request for correction / change of data / services;
  • Servicing and responding to customer complaints / inquiries. Adjustments of amounts due on already realized reservations for accommodation and meals in the presence of grounds for this;
B) In fulfillment of its legal obligations, „BUSINESS CLUB - VALENTINA PETROVA“ EOOD processes your data for the following purposes:
- Providing information to the Ministry of internal affairs, the competent municipality of the location of the hotel, The Commission for Consumer Protection and the Commission for Personal Data Protection, in connection with the fulfillment of our obligations as a hotelier, arising from the current regulations in this area;
- Processing of your data in invoices issued in your name for other purposes compatible with the original purpose of collecting them.
- Carrying out tax and social security control by the respective competent governmental bodies;  
- Providing information to the court and third parties within the scope of the proceedings before the court, in order to protect its legal interests, including collection of receivables from clients through court proceedings;      
C) “BUSINESS CLUB – VALENTINA PATROVA” EOOD processes your data also for the purposes of our following legitimate interests:
- For the purposes of direct marketing- sending offers containing information about our current offers, promotions and discounts for accommodation in our hotel and/or changes in the conditions of the already used ones;
- To include your name, photos, videos and other data in brochures, website and more in publications of "BUSINESS CLUB - VALENTINA PETROVA" EOOD as a result of your participation in organized by us group events and activities in our hotels (dancing, sports and other entertainment).
- To protect, exercise or preserve the legal rights, integrity, safety or property of the administrator, users of the administrator's services and members of the public;
3. Categories of third parties that access and process your personal data: In connection with carrying out our activities and the fulfillment of our contractual commitments with our customers, we provide your data to the following groups of "recipients", namely:   
- To the data subject– always, when they exercise their right;   
- To the users/clients, for which this data is concerned;  
- To business partners – for the purposes of fulfilling the made by you reservations: travel agents and representatives in Bulgaria and abroad, transportation companies and airlines, providers of the corresponding basic and additional tourist services, and other subcontractors, with which we have signed contracts;
- Payment service providers for online payments with credit cards;
- Insurance companies when claiming that an insurance event has occurred with a tourist staying at our hotel;
- IT companies maintaining information systems, our company’s website, software and platforms for managing the reservations of our clients and others;
- To public authorities (Ministry of Internal Affairs, municipality, NRA, Consumer Protection Commission, Personal Data Protection Commission, judicial and other control authorities);
Other administrators of personal data to whom “BUSINESS CLUB - VALENTINA PETROVA” EOOD provides your personal data on a legal basis and/or on the basis of a bilaterally signed contract.  
It may be necessary - by law, in litigation and/or at the request of public and governmental authorities in or outside your country of residence, as well as for national security, law enforcement or other matters of public importance, that we disclose your personal information when such disclosure is necessary or appropriate.
We may also disclose information about you, if we find that such disclosure is justified and necessary for the application of our company terms and conditions, or to protect our activities, legal interests and the rights and legal interests of other users. In addition, in the event of a reorganization, merger or sale, it is possible to transfer any and all of the collected database to the relevant successor third party.  
4. For how long is your personal data stored. Safety:
The duration of storing your personal data depends on the purposes of processing, for which they are gathered:
  • Your personal data, processes with the purpose of providing and fulfilling tourist services for accommodation and food in our Hotel, are stored for the duration of 3 (three) years, as of the date of your departure from the hotel, also as of the final settlement of all financial relations between the parties, observing the statutory deadlines, when there are such;  
  • The personal data, processed with the purpose of issuing of accounting/financial documents for tax and social security control, as well as but not only - invoices, debit, credit notices, are stored for at least 3 (three) years, unless the applicable legislation provides for a longer term.
Video recording from security cameras – up to 180 days from creating the recording.  
The storage of personal data for longer periods is possible to protect the legitimate interests of "BUSINESS CLUB - VALENTINA PETROVA" EOOD,  as well as until the expiration of the relevant statute of limitations in order to protect any claims of customers in connection with the implementation / termination of tourist services for accommodation and food in our hotel, as well as for a longer period in case of a legal dispute has already arisen - the documents are stored until its final resolution with an effective court / arbitration decision.
As Administrator of personal data - "BUSINESS CLUB - VALENTINA PETROVA" EOOD takes due care and takes the appropriate and required by law administrative, technical and physical measures, as well as those related to staff / training, awareness, etc./ to protect the information at its disposal, including the protection of personal data of its customers from loss, theft and unauthorized use, disclosure, modification and any other illegal forms of processing. We have physical, electronic and procedural safeguards that comply with our legal obligations regarding the protection of personal data and which we maintain in accordance with the latest technological advances.
We are responsible for the protection of personal data of the client, which became known to us on the occasion of carrying out our activity as a hotelier and in providing our tourist services, specified in the subject of the General Conditions and this Policy, except in cases of force majeure, accidental event or malicious actions of third parties, as well as in cases where the client has made this information available to third parties.
5. Video surveillance
The common areas of our hotel are subject to 24-hour video surveillance, which is carried out by stationary security cameras located at the respective places.
The video surveillance is carried out 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, inviolability and safety of hotel guests and members of society.
The video surveillance is organized and controlled by employees of the administrator, specially trained for data protection.
The recordings are stored on video servers for a period of 180 days, except in case of a registered violation of the rights of the administrator, the tourists or third parties, in which case the term of keeping the recordings may be extended according to the specific needs.
You have the right to request to review the records if you allege a breach of rights that apply to you or a supervised by you person, and your request will be considered within the time limits set out in section 6 of this policy.
The Company may refuse to consider requests that are unreasonably repeated, require disproportionate technical effort or jeopardize the privacy of other users.
 
6. What are your rights in connection with the processing of your personal data by “BUSINESS CLUB – VALENTINA PETROVA” EOOD and what actions should you take to exercise them:
- The right to access to the data relating to him - the client has the right at any time to ask us for confirmation of whether data relating to him are processed, information on the purposes of such processing, on the categories of data and on the recipients or categories of recipients, to whom the data are disclosed;
- The right to correct and update their personal data when they are inaccurate or incomplete in view of the purposes of their processing;
- Right to erasure (the right to be "forgotten") when his data is processed illegally or with no grounds (the original purpose for which they were collected and processed has been fulfilled, storage period has expired (including limitation period), withdrawn consent for processing, you have objected to their processing, etc.), there is no other reason for their processing or national or European legislation requires it;
- Right to limit the processing - in the presence of a legal dispute between "BUSINESS CLUB - VALENTINA PETROVA" EOOD and the individual until its resolution and / or for the establishment, exercise or protection of legal claims; where the processing is unlawful but the data subject does not wish the personal data to be deleted but instead requests that their use be restricted; in case of an objection made by you against the processing of your personal data for the term of the verification of its validity;
- Obligation to notify when correcting or deleting personal data or restricting the processing - the customer has the right to require us to notify third parties to whom his personal data has been disclosed of any deletion, correction or blocking of such data, with the except of cases, when this is impossible or is associated with excessive efforts for "BUSINESS CLUB - VALENTINA PETROVA" EOOD.   
- Right to be notified of a breach of personal data security - in cases where the breach of data security is likely to pose a high risk to the rights and freedoms of individuals. We are not required to notify you if: we have taken appropriate technical and organizational measures to protect the data affected by the security breach, and if we have subsequently taken measures to ensure that the breach will not lead to a high risk of your rights and if the notification would require a disproportionate effort.
- Right to object to the processing of your personal data - at any time and on grounds related to the specific situation of the person, provided that there are no convincing legal grounds for the processing, which take precedence over the interests, rights and freedoms of the subject of data, or litigation.
When processing personal data for the purposes of direct marketing, the User has the right at any time to object to the processing of personal data, relating to him for this type of marketing, which includes profiling, as far as it is related to direct marketing. At the latest at the time of the first contact with the consumer, he shall be explicitly informed of the existence of the right of objection described above, which shall be given to him by notification in a clear manner and separately from any other information.
Right to judicial and administrative protection - the right to file a complaint to a supervisory authority, the right to effective judicial protection against a supervisory authority, the right to effective judicial protection against an administrator or processor of personal data; right to compensation for suffered damages.
Procedure for exercising the rights: You can exercise all your rights regarding the protection of your personal data through the forms attached to this Policy, which you can download here. Of course, these forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data holder.
"BUSINESS CLUB - VALENTINA PETROVA" EOOD considers and rules on the request of the User in accordance with the requirements of applicable law with as short as possible deadlines and in any case within 1 / one / month of receipt of the application. If necessary, this period can be extended by another 2 / two / months, given the complexity and number of applications. BUSINESS CLUB - VALENTINA PETROVA EOOD informs the user about any such extension within one month of receiving the application, indicating the reasons for the delay.
Information about the supervisory authority:
COMMISSION FOR PROTECTION OF PERSONAL DATA / CPDP /,
city Sofia 1592, blvd. “Professor Cvetan Lazarov” №2,
tel. 02/91-53-518, fax: 02/91-53-525,
e-mail: kzld@cpdp.bg
www.cpdp.bg
7. Can you refuse to provide personal data to “BUSINESS CLUB - VALENTINA PETROVA” EOOD and what are the consequences of this?
In order to fulfill the reservation made by you and to provide you with the requested accommodation services in our hotels, we need certain data, which are regulated by the legislation in force in the Republic of Bulgaria.
Failure to provide the information specified in item 2.1. personal data, prevents the possibility of "BUSINESS CLUB - VALENTINA PETROVA" EOOD to accept your reservation and, respectively, to provide you with the requested services on site in our hotels.  
8. Our policy on using cookies (Cookie Policy)
"BUSINESS CLUB - VALENTINA PETROVA" EOOD uses the so-called "cookies" on its website www.vpbusiness.club, which are important for its proper operation. By visiting our site, you accept the use of cookies.
Types of cookies, that we use:
  • Mandatory cookies - these cookies are necessary for the correct operation of the website. For example, with these cookies we show you the information on our site, photos, videos, etc., as well as they help the proper functioning of the search engine so that you do not have to enter the same information on different pages. These cookies are temporary and are deleted when you close your browser.
  • Analytical cookies - thanks to these cookies we monitor the traffic to our site and we can analyze how easily our users work with it (Google Analytics cookies). These cookies do not give us any information about your personal data. They show us which pages of our site are viewed, whether our site is visited via a mobile or desktop device and other anonymous data.
  • You can set the cookies that you receive from our site in the browser you use. Please note that if you restrict certain types of cookies, our site may not work fully or correctly and you may not be able to use its full functionality.
9. CANGES TO THE PRIVACY POLICY
“BUSINESS CLUB- VALENTINA PETROVA” EOOD has the right to, when circumstances dictate this, unilaterally to update, change and add to the policy for protection of personal data, at any time in the future. Any addition or change to this Policy will be published on the company’s website www.vpbusiness.club and/or will be given to the clients on request.  
This policy has been updated last on 25.07.2020.
 
 
Our goal is to offer the highest level of service to our guests and clients, by giving them the opportunity to enjoy their stay at hotel "Business Club" combining business and leisure.
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