Dear guests,
Villa Geronimo Ltd., UIC 131429205, with registered address at 22 Gurgulyat Str., Floor 3, Ap. 15, Sofia, applies the General Data Protection Regulation 2016/679 of the European Commission, in force since 25.05.2018.
PRINCIPLES OF PROCESSING PERSONAL DATA
The policy of VILLA GEROINIMO aims to ensure compliance with the provisions of the Regulation.
VILLA GEROINIMO collects and processes personal data lawfully, fairly, and in accordance with the principles and rights of individuals regarding the processing of their personal data.
VILLA GEROINIMO processes personal data of individuals only in the following cases:
- The processing is necessary for compliance with a legal obligation of VILLA GEROINIMO.
- The processing is necessary for the performance of a contract (including an order) with VILLA GEROINIMO to which the data subject is a party, or for taking steps at the request of the data subject prior to entering into a contract when their identification is necessary.
- The data subject has given their explicit consent for a specific, clearly defined purpose by VILLA GEROINIMO, for which processing of their personal data is required.
- The processing is necessary to protect the vital interests of the data subject or another natural person.
- The processing is necessary for the purposes of the legitimate interests pursued by VILA DZHERONIMO or by a third party, in accordance with the provisions of the Regulation.
- Other cases provided for in the Regulation.
Villa Geronimo does not collect or process personal data of individuals beyond its legal obligations or business needs.
In all cases where it is necessary to use collected and processed personal data of individuals for purposes other than the initial ones, Villa Geronimo informs the respective individuals, requests their consent, and proceeds with the processing of their personal data for other purposes only after obtaining their explicit consent.
Villa Geronimo collects and processes only the minimum necessary personal data of individuals, which:
- are provided for by law;
- are necessary for the performance of a contract;
- are necessary to achieve the purposes for which they are collected.
VILA GERONIMO ensures that the processing of personal data of individuals is carried out with maximum accuracy and, wherever possible, always kept up to date.
VILA GERONIMO ensures that access to and processing of personal data of individuals are carried out by the minimum necessary number of persons (operators) who have the required competence for their processing and the necessary commitment to their protection.
STORAGE PERIODS
VILA GERONIMO stores personal data for the following periods:
- Data from the register of accommodated tourists as defined in Article 116 of the Tourism Act, which includes identification data of the accommodated individuals and data related to hotel accommodation, are stored in accordance with the provisions of the Tourism Act and the relevant secondary legislation, in terms of procedure and deadlines.
- Information related to requested and used accommodation services, events, and services, including canceled accommodation reservations (to the extent that they are related to refunding prepaid amounts and/or withholding due amounts), is retained from the time of the respective reservation/request for up to 5 (five) years from the provision of the service/termination of the contract/cancellation of the reservation. In cases where the services are requested and used based on a contract with continuous performance, the period starts from the final performance and/or termination of the contract.
- Financial and accounting documents, invoices, authorization forms, and other information related to tax and social security control are kept for up to 10 (ten) years from the beginning of the year following the year in which the payment obligation for the respective year arises.
- Unstructured communication, correspondence, complaints, signals, and similar documents are retained for 5 (five) years.
- Data from video recordings is retained for up to 1 week.
- Data processed based on the explicit consent of the Data Subject is retained from the moment of providing consent until its withdrawal by the Data Subject.
- Until requested by the individual for their deletion, when there is a basis for such a request.
The personal data specified in this Policy may be processed for a longer period than indicated above if necessary to achieve the purposes outlined therein or to protect the rights and/or legitimate interests (including by legal means) of VILA GERONIMO, or if the applicable legislation provides for the processing of data for a longer period.
In all cases, VILA GERONIMO ensures that at least once a year, a review is conducted of the collected and processed personal data, and those falling under any of the above hypotheses are deleted without undue delay.
RULES FOR PROCESSING PERSONAL DATA
- Personal data is processed with the necessary levels and measures of protection.
Villa Geronimo ensures the necessary levels of physical, organizational, and technological protection in order to:
- the nature, scope, context, and purpose of the processed personal data;
- the probability, the impact levels, and the severity of risk to the rights and freedoms of individuals in the event of a security breach of the processed personal data;
- its financial and organizational capabilities.
VILLA GERONIMO also ensures all necessary measures for timely recovery of collected and processed personal data in case of loss due to accidental, intentional, or force majeure events.
- Personal data is processed with controlled and traceable access.
VILA GERONIMO ensures the necessary and appropriate technical, organizational, and technological measures for controlled and traceable access to the personal data of individuals.
- Personal data is processed with the necessary accountability to comply with the Regulation.
VILLA GERONIMO ensures the necessary reporting and records to be able to demonstrate compliance with the Regulation.
SUBJECTS OF DATA
In relation to the provided services, VILA GERONIMO processes information regarding the following Data Subjects:
- Individuals visiting the website. http://www.villageronimo.bg/;
- Individuals making reservations on their own behalf or on behalf of another individual or legal entity through the Website.
- Individuals using the services provided by VILLA GERONIMO, including but not limited to accommodation services and related services, as well as individuals representing or acting on behalf of legal entities using these services.
- Individuals who have submitted inquiries (including but not limited to via email, phone calls, using Messenger on the Facebook page of the establishment, etc.), requests, complaints, or other correspondence to VILLA GERONIMO, either on their own behalf or on behalf of another person they represent.
- Individuals whose information is contained in inquiries (including via phone calls or using Messenger on the Facebook page of the establishment), requests, complaints, or other correspondence to VILLA GERONIMO.
- The services of VILLA GERONIMO can only be requested by legally competent individuals who have reached the age of 18.
RIGHTS OF INDIVIDUALS WHOSE DATA IS PROCESSED:
VILA GHERONIMO ensures compliance with the rights of individuals whose personal data is collected and processed, including:
- The right to be informed about the processing of personal data:
- The right to access personal data – what data is available;
- The right to rectification of inaccurate personal data:
- The right to erasure of personal data – the right to be forgotten;
- The right to restrict processing of personal data;
- The right to be informed about actions taken as a result of a request for correction, erasure, or restriction of processing of personal data;
- The right to data portability;
- The right to object to the processing of personal data;
- The right not to be subject to automated decision-making, including profiling.
PROCESSED PERSONAL DATA
Processed Personal Data as Controller:
- on employees;
- on individual clients;
- on individual suppliers;
PURPOSES OF PROCESSING PERSONAL DATA
VILA GERONIMO as the Controller, performs the following operations and processes only the necessary personal data for the following purposes:
- For the conclusion, execution, and termination of employment contracts and the calculation of salaries and compensations for employees.
- For the acceptance, administration, and processing of reservations, as well as cancellations thereof.
- For the administration, execution, and delivery of purchases made through the website.
- Administration and receipt of payments for the services provided, including remote payments.
- Providing services to customers.
- Ensuring a personalized approach to providing services, tailored to the preferences stated by the users.
- For entering into and executing contracts with physical persons acting as suppliers.
- For direct marketing for sales purposes.
RECIPIENTS AND CATEGORIES OF RECIPIENTS
In connection with the fulfillment of the purposes mentioned above, VILA GERONIMO provides personal data to individuals in the following categories:
- NRA in relation to the calculation of staff salaries;
- NSSI in connection with the calculation of staff benefits;
- Occupational health service provider for maintaining the current health status of the staff and conducting periodic medical examinations.
- Main Inspectorate of Labor, National Social Security Institute (NSSI), and Ministry of Interior (MVR) – in connection with occupational accidents.
- Ministry of Interior (MVR) – in connection with transmitting information about guests of the tourist facility.
- Other state and municipal authorities and/or institutions – in connection with legal obligations towards them or in response to legal requests from them for information containing personal data.
- Subcontractors for the performance of contractual obligations.
VIDEO SURVEILLANCE AND SECURITY
In accordance with applicable legislation, VILLA GERONIMO implements security measures, including the following technical and organizational measures to control access and ensure physical security against intrusions into the buildings and premises, and to protect the life and health of citizens: a video surveillance system that conducts 24-hour video surveillance and consists of recording and storing devices.
Video surveillance and recording may be conducted in publicly accessible areas and premises within the buildings of VILLA GERONIMO and in those areas for which a special access regime is provided. Video surveillance is not conducted in guest rooms, sanitary-hygienic facilities, relaxation areas, etc. Data from video surveillance activities are stored for a period of seven days.
CONTACT DETAILS OF THE COMPANY
If you have any questions or uncertainties regarding the processing of your personal data or if you wish to exercise any of your rights, you can contact us at:
COMPETENT SUPERVISORY AUTHORITY
On the territory of the Republic of Bulgaria, the competent supervisory authority is the Commission for Personal Data Protection.
If you suspect that your rights related to the protection of your personal data have been violated, you can report it to:
- Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
- E-mail: kzld@cpdp.bg
- Website:cpdp.bg
