Privacy Policy
This Privacy Policy is based on the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
GENERAL PROVISIONS:
As you agree that the data provided by you is processed and processed by your activities, “ALPIN PROPERTY GROUP” EOOD (hereinafter in this Privacy Policy “DOM NA ALPINISTA”) as an administrator of personal data of your clients – physical persons, as well as personal data of other persons related to you, (.”Subjects of data”) in compliance with the relevant regulations of this Privacy Policy and Principles.
(2) “ALPIN PROPERTY GROUP” EOOD is a company with VAT number 206216850, with headquarters and address for management in Sofia 1415, district “Vitosha”, str. “Mavrovets” No. 28, tel .: address of email:
(3) “DOM NA ALPINISTA” processes personal data throughout the course of business and determines the purposes and means of processing them. In this case, “DOM NA ALPINISTA” acts as a personal data administrator.
(4) In cases where “DOM NA ALPINISTA” processes personal data for purposes determined independently by a third party or the purposes are determined jointly by “DOM NA ALPINISTA” and a third party, “DOM NA ALPINISTA” has the status of either a personal data processor (if the purposes are determined by the person who commissioned the processing) or a co-administrator.
Article 2. According to these rules, “DOM NA ALPINISTA” strives to organize the organization of processing and protection of personal data of its clients – physical persons, as well as all other groups of persons with whom “DOM NA ALPINISTA” enters into relationships in connection with the implementation of legal assistance and activities.
Article 3. (1) “DOM NA ALPINISTA” is an administrator of personal data according to Article 4, t. 7 of General Regulation on the protection of data (EC) 2016/679 and Law on the protection of personal data.
(2) As an administrator of personal data, “DOM NA ALPINISTA” complies with the principles for the protection of personal data provided in the General Regulation on the protection of data (EC) 2016/679 (“Regulation”), as well as the legislation of the European Union and the Law on the Protection of Personal Data.
PRINCIPLES FOR THE PROTECTION OF PERSONAL DATA
Lawfulness
Article 4. “DOM NA ALPINISTA” processes personal data only when there is a basis for a specific processing or when the subject of data has given express consent for processing.
Article 5 (1) Processing of data on the basis of the consent of the subject shall be considered to exist when the subject has not received processing for the purposes of the legitimate interest in “DOM NA ALPINISTA”;
(2) In cases where data of children under 14 years of age are processed, such processing shall be lawful only if and to the extent that such consent is given by the parent or guardian responsible for the child;
(3) In order to fulfill and prove the fulfillment of the obligation of “DOM NA ALPINISTA” for the existence of informed consent, data subjects are provided with a Declaration of consent for the processing of personal data;
(4) “DOM NA ALPINISTA” ensures the possibility of the subject of data at any time to withdraw their consent for processing of data
Good faith and Transparency
Article 6. (1) In the implementation of the requirements for good faith and transparency of processing, as a person follows that at any beginning referred to data subjects to which personal data, namely used, processed or processed by another beginning, as well as in what is involved or whether such, “DOM NA ALPINISTA” informs data subjects of that processing.
Legal determination of purposes and supplementary processing.
Article 7. (1) Data that “DOM NA ALPINISTA” collects are connected exactly determined by law (by rule) or by “DOM NA ALPINISTA” (by exception) purposes
(2) Supplementary processing is permitted only for the purposes of archiving or for statistical purposes, when there is no incompatibility of the subsequent purposes
Data minimization
Art. 8. “DOM NA ALPINISTA” does not require the provision of more data than necessary, based on the minimum required by law, and where no such legal requirement exists, compliance with this principle is the responsibility of the administrator, who determines the amount of information required from the subjects of the personal data.
Accuracy
Art. 9. “DOM NA ALPINISTA” provides the opportunity to update inaccurate and incomplete data in accordance with the procedure for exercising the right of correction. “DOM NA ALPINISTA” strives to ensure that the data it processes is accurate and complete. In connection with compliance with this principle, data subjects may request the updating and correction of their personal data.
Storage limitation
Art. 10. (1) “DOM NA ALPINISTA” stores personal data only for the time necessary to perform the activities for their processing and/or the functions and purposes of the hotel, unless a regulatory act requires another period for their storage.
(2) Once the purposes for which the data were collected have been achieved, after the storage period has expired, at the request of the data subject (if applicable) or as necessary, the data shall be destroyed in a manner that does not allow their recovery.
Integrity and confidentiality
Art. 11 “DOM NA ALPINISTA” processes personal data in a manner that ensures an appropriate level of security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by implementing appropriate technical or organizational measures.
Security of personal data when processed by third parties
Art. 12. (1) DOM NA ALPINISTA requires technical and organizational measures to be taken by those processing personal data on its behalf, which are included in the contract with each processor. The processor shall demonstrate the necessary level of personal data protection in accordance with the level of protection determined by DOM NA ALPINISTA.
Accountability and Documentation
Art. 13. In accordance with the principle of accountability, “DOM NA ALPINISTA” documents the fulfillment of all its obligations for the protection of personal data.
PURPOSES OF PERSONAL DATA PROCESSING
Art. 14. Depending on the legal basis for personal data processing, DOM NA ALPINISTA collects, stores, and processes the information described in this Policy on the following grounds and for the following purposes:
1. Purposes related to compliance with the legal obligations of DOM NA ALPINISTA;
2. Purposes related to and/or necessary for the performance of contracts concluded with DOM NA ALPINISTA or for taking steps at the request of the Data Subject prior to entering into a contract;
3. Purposes of the legitimate interest of DOM NA ALPINISTA or third parties;
4. Purposes for which the Data Subject has consented to the processing of their data, including:
(a) Sending marketing and advertising messages about services, special offers, packages, events, and other similar items;
(b) Surveys on the quality of services;
(c) Sending newsletters;
(d) Other purposes for which the Data Subject has specifically given consent.
DATA SUBJECTS
Art. 15. In connection with the services provided, DOM NA ALPINISTA processes information about the following Data Subjects:
1. individuals visiting the website;
2. individuals who make reservations on their own behalf or on behalf of another individual or legal entity through the Website;
3. individuals using the services provided by DOM NA ALPINISTA, including, but not limited to, hotel accommodation, catering and related services, provision of premises for conferences and other events, and other similar services; as well as individuals representing or otherwise acting on behalf of legal entities that use these services;
4. individuals who have sent inquiries, requests, reports, complaints, or other correspondence to DOM NA ALPINISTA on their own behalf or on behalf of another person they represent;
5. individuals whose information is contained in inquiries (including by telephone), requests, reports, complaints, or other correspondence to DOM NA ALPINISTA.
CATEGORIES OF PERSONAL DATA:
Art. 16 (1) Data related to the provision of hotel accommodation services:
(a) Identification data: First name, middle name, last name, personal identification number, nationality, email address, telephone number, and address;
(b) Contact details: telephone number; email address; address;
(c) Information about the stay, including arrival and departure dates, details of any special requests made;
(2) Financial information or billing details – name of legal entity; address of legal entity; VAT number and/or other tax or registration number (for sole traders and individuals), card type and number, cardholder name, expiry date, and other information provided by the card-issuing bank.
(3) Digital data – video recordings: This is data collected through the video surveillance systems used by DOM NA ALPINISTA in all publicly accessible areas of the hotel (foyer, reception, restaurant, lobby bar, corridors, staircases, entrances) for the purposes of security, surveillance, control, and protection of public order.
(4) In connection with the provision of restaurant services:
(a) Identification data: names.
(b) Contact details: telephone number; email address; address.
(c) Financial information or data for issuing an invoice – name of the legal entity; address of the legal entity; VAT number and/or other tax or registration number (for sole traders and individuals), card type and number, cardholder name, expiry date, and other information provided by the card-issuing bank.
(d) Information related to the customer’s special preferences and requirements regarding the service provided;
(5) In relation to the services and functionalities of the Website:
(a) Data processed in connection with making a hotel reservation: names; telephone number; address; email address, nationality; name and information about the legal entity; number of rooms; number of guests, including number of adults and number of children; special offers and guest preferences (if explicitly specified when booking);
(b) Cookies: Cookies are necessary for the functioning of the Website. A detailed description of the cookies used, their purpose, and the information processed through them can be found on the DOM NA ALPINISTA website, in the “Cookie Policy” section.
(6) In connection with complaints, statements, requests, petitions, and reports submitted by customers (including in free text): information contained in the relevant complaints, statements, requests, petitions, and reports.
VIDEO SURVEILLANCE AND SECURITY
Art. 17 (1) In accordance with the requirements of the applicable legislation, DOM NA ALPINISTA implements security measures that include the following technical means for access control and for ensuring security against encroachment on buildings and facilities and for protecting the life and health of citizens: security alarm systems and a video surveillance system providing 24-hour video surveillance and consisting of recording and storage devices.
(2) Video surveillance and video recording may be carried out in publicly accessible areas and premises in the buildings of “DOM NA ALPINISTA” and in those for which a special access regime is provided. No video surveillance is carried out in guest rooms, sanitary facilities, recreation rooms, etc.
(3) Data subjects and other visitors who may be filmed shall be notified of the use of technical means of surveillance and control and of any other related information in connection with the surveillance carried out by means of information boards placed in a prominent place.
REFUSAL TO PROVIDE PERSONAL DATA TO “DOM NA ALPINISTA”
Art. 18. (1) “DOM NA ALPINISTA” shall clearly indicate, where applicable, whether the provision of the relevant data and/or documents is mandatory for the conclusion or performance of a contract, as well as the consequences of refusal to provide them.
(2) If additional information is required, each Data Subject may request it at the premises of DOM NA ALPINISTA or send an inquiry to the contacts specified in Article 23 of this Policy.
(3) Refusal to provide data and documents by the Data Subject, when they are specified as mandatory, may constitute an insurmountable obstacle to the provision of a service by DOM NA ALPINISTA, as well as to the addressing of submitted requests, applications, petitions, signals, etc. In such cases, DOM NA ALPINISTA shall be released from liability for non-performance.
(4) The provision of false data and documents may result in the inability to provide the relevant services or in the suspension of access to services provided by DOM NA ALPINISTA.
PROCESSING OF INFORMATION BY THIRD PARTIES – PROCESSORS OF PERSONAL DATA
Art. 19. (1) For the purposes specified in this Policy and in connection with the services provided, DOM NA ALPINISTA may assign personal data processing activities to third parties – personal data processors, in accordance with and within the requirements of the Regulation and this Policy.
(2) In the event of disclosure and processing of data by a third party – a processor, this shall only be done to the extent and to the extent necessary for the performance of the tasks assigned to them by DOM NA ALPINISTA.
(3) Personal data processors act on behalf of DOM NA ALPINISTA and are obliged to process personal data solely and exclusively in strict compliance with the instructions of DOM NA ALPINISTA, and shall not have the right to use or process the information in any other way for purposes other than those specified in this Policy.
RIGHTS OF DATA SUBJECTS
Article 20. (1) Every Data Subject is entitled to the following rights in connection with the processing of collected personal data:
1. Right to Information – to obtain confirmation that personal data is being processed, as well as obtain information regarding the source of the processing;
2. Right to Access – to obtain access to processed personal data and detailed information regarding data processing and their rights;
3. Right to Correct – to request correction or deletion of personal data if it is incomplete or incorrect;
4. Right to erasure – to request the erasure of his/her personal data if there are grounds for doing so;
5. Right to restriction of processing – The data subject has the right to request the controller to restrict processing when he/she considers that the data is inaccurate or is being processed unlawfully;
6. Right to data portability – to receive the personal data concerning him/her that he/she has provided to , in a structured, commonly used, DOM NA ALPINISTA and machine-readable format, and to transfer that data to another controller without hindrance from DOM NA ALPINISTA
Right to Data Portability applies when the following two conditions:
(a) Processing is based on explicit or contractual undertaking; and
(b) Processing is carried out by automated means.
7. Right to Withdraw Consent – where processing of personal data is based solely on the consent given by the Data Subject, the subject may withdraw the consent at any time. Withdrawal does not affect the legality of the processing until the moment of withdrawal;
8. Rights in relation to automated individual decision-making, including profiling – not to be subject to a decision based solely on automated processing (i.e., processing without human intervention), including profiling within the meaning of the Regulation, which produces legal effects concerning the Data Subject or similarly significantly affects him or her, unless there are grounds for doing so in the Regulation and appropriate safeguards are in place to protect the rights and freedoms and legitimate interests of the Data Subject. Such safeguards shall include at least the right to human intervention, the right of the Data Subject to express his or her point of view and to contest the decision.
9. Right to object – The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to object to the processing of personal data concerning him or her, including profiling within the meaning of the Regulation, which is based on public interest, the exercise of official authority, or the legitimate interests of DOM NA ALPINISTA or a third party. In such cases, DOM NA ALPINISTA shall cease processing the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the Data Subject or for the establishment, exercise, or defense of legal claims.
Art. 21. The ADMINISTRATOR shall ensure conditions that guarantee the exercise of these rights by the data subject:
(1) The Data Subject may exercise their rights, associated with the protection of personal data as a natural person, accordingly in written form addressed to “DOM NA ALPINISTA” – at the address specified in Art. 23 of this Policy or by email, sent to the address indicated on the website.
(2) Request pursuant to Art. 1 may be exercised in electronic form, and for the price which the request must be signed by the Data Subject with a qualified electronic signature and sent to “DOM NA ALPINISTA” at the email address indicate Policy in Art. 23 of this
(3) Data Subjects have the right to lodge a complaint to ADMINISTRATOR, through the official person for the protection of personal data, linked with the processing of their data.
(4) Data Subjects may exercise the right, associated with their personal data, in person or through a representative or otherwise authorized person.
Supervisory authority in Republic of Bulgaria
Art. 22. The supervisory authority in the Republic of Bulgaria is:
Personal Data Protection Commission
Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd. Website:
Article 23. Data subjects can obtain information about content and source of personal data, as well as on the exercise of rights under this Policy, as well as any additional information about the processing of personal data from “ALPIN PROPERTY GROUP” EOOD at:
Address: Hotel “Dom na Alpinista”, Vratsa, Markov Kamak area
Email address: gm@domnaalpinista.bg
Phone: +359 87 670 0048
Personal Data Protection Officer: Savva Chulkov