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Privacy policy Odrys Apartments, Plovdiv, Bulgaria

In Odrys Apartments, Plovdiv - managed by Iveka 2000 Ltd. - we make every effort to protect the privacy of your personal data. The purpose of this privacy policy is to inform you what personal data we process about you when providing and administering our services, for what purposes and what rights you have as a data subject under the requirements of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Controller of your personal data (also referred to as "data")

Iveka 2000 Ltd.
Head office: 4199 Trud, Mestnost Gerena 62036, Plovdiv аrea, Bulgaria
E-mail:
Phone number: +359 / 896 280 008

I. Administration of reservations and accommodation of guests:

Personal data processed

Within the administration of your reservation and stay, we process following personal data:

  • Contact information – name, surname, telephone number; e-mail address - in particular cases
  • Gender
  • Date of birth
  • Personal identification number (resp. issued for Bulgarian or foreign citizens)
  • Number of identity card / passport / driving license
  • Nationality
  • Period of stay
  • Data regarding minor children – name, surname, gender, date of birth; additionally for children of foreign nationality - passport number and nationality
  • Financial information, such as payment and billing information, including credit card details - when paying for our services directly on-site.

Purposes of processing

  • Communication with you in relation to your reservation, accommodation and stay; confirmation and administration of the reservation;
  • Maintenance of a mandatory register of the accommodated tourists in the legally defined scope with the content approved by the Minister of Tourism of the Republic of Bulgaria;
  • Conduction of payments, billing for the use of our services, accounting purposes;
  • Collection of outstanding debts; resolving legal litigations; establishing, exercising and defending legal claims;
  • Assisting law enforcement authorities in case of violation of legal norms - where necessary and in cases provided by law; complying with other relevant legal requirements, such as Compliance Screenings to prevent economic crimes or money laundering - as applicable in individual cases.

Processing of personal data for other purposes may only be considered if the requirements according to Article 6 para. 4 of Regulation (EU) 2016/679 are fulfilled; here we will comply with the information obligations defined in Article 13 para. 3 of Regulation (EU) 2016/679 and Article 14 para. 4 of Regulation (EU) 2016/679.

Legal basis for processing your data

  • Performance of a contract or in order to take steps prior to entering into a contract (Article 6 para. 1 point b) of Regulation (EU) 2016/679)
  • Compliance with a legal obligation (Article 6 para. 1 point c) of Regulation (EU) 2016/679)
  • Legitimate interests of the controller (Article 6 para. 1 point f) of Regulation (EU) 2016/679) - economic interests. You have the right to object to the processing on grounds relating to your particular situation on the basis of Article 6 para. 1 point f) of Regulation (EU) 2016/679.

We process your data solely to the extent to which this is necessary in order to fulfil the above listed purposes.

Data sources

The personal data processed is provided by the individuals to whom it relates; in case of booking through external online booking platforms with which the controller has a contract (e.g. Booking.com), we receive from them the contact information related to the guest (name and surname, country of residence; resp. telephone number or address - if available оn the external booking platform).

Categories of recipients

Within the administration of our services and the accommodation of guests, we transmit your data to:

  • The Unified Tourist Information System of the Bulgarian Ministry of Tourism for the purpose of compulsory registration of guests - based on current Bulgarian legislation;
  • Courts of law, courts of arbitration, state and law enforcement authorities - only in the cases provided for by law and to the extent that it does not exceed the purposes for which it was requested or for the establishment, exercise or defence of legal claims;
  • The relevant service providers used to achieve the purposes stated above and in the privacy policy for our website.

Your rights in relation to the processing of your personal data

  • Information/access to your data;
  • Rectification and completion of data;
  • Restriction of processing if: 1) you dispute the correctness of your data; 2) the processing is unlawful and instead of deletion you demand its restriction; 3) we do not need your personal data any longer, but you need it for establishment, exercise or defend of legal claims; 4) you have raised an objection pursuant to article 21 (1) of Regulation (EU) 2016/679 – in this case your rights and our rights have to be weighed against each other; as long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your data;
  •  Erasure of your data, in particular in any of the following cases: the data is no longer necessary for the purposes set out in this policy; the data has been processed unlawfully; you have withdrawn your consent and there is no other legal basis for the processing; you have objected to the processing and there are no overriding legitimate interests for proceeding with it;
  • Objection to processing of your data at any time based on legitimate interests, on grounds relating to your particular situation. In the event of a reasoned objection, we will cease processing unless we can demonstrate compelling legitimate interests for it which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
  • Right to data portability – you have the right to receive your data in a structured, accessible, machine-readable format, and have your data transmitted from us directly to another controller.
  • Withdrawal of your consent to processing at any time with effect for the future – if you have given your consent. The lawfulness of processing based on your consent before its withdrawal will not be affected by your withdrawal.

Furthermore, you have the right to lodge a complaint with the competent supervisory authority or to an effective judicial remedy if you consider that the processing of your personal data violates Regulation (EU) 2016/679.

Automated individual decision-making

Within the scope of processing, we do not use fully automated decision-making pursuant to Article 22 of Regulation (EU) 2016/679.

Transfer of personal data to third countries

The transfer your personal data to third countries or international organisations outside the European Union, respectively the European Economic Area, may take place if the European commission has decided that the third country ensures an adequate level of protection; if such decision is not available, the transfer may take place only if there are appropriate safeguards and if enforceable data subject rights and effective legal remedies are available. In the absence of an adequacy decision or appropriate safeguards a transfer may take place based on the derogations pursuant to Article 49 of Regulation (EU) 2016/679, for example: 1) if you have explicitly consented to the proposed transfer; 2) the transfer is necessary for the performance of a contract with the controller or the implementation of pre-contractual measures; 3) the transfer is necessary for the conclusion or performance of a contract concluded in your interest between the controller and another natural or legal person.

The transfer of personal data to third countries is described in the relevant cases in the privacy policy for our website.

Data retention period and erasure

We process your data as long as necessary to achieve the relevant purpose for which it was provided. Personal data processed for the purpose of address registration as well as financial information is retained until the expiry of statutory retention periods; data that is retained for the purpose of administering our services is retained until the expiry of periods of limitation for making claims. After the expiration of these time limits, if there is no further necessity for processing, your data will be deleted.

Data storage periods within the usage of our website are described in the relevant cases in the privacy policy for our website.

Тechnical and organisational measures for data protection

We make every effort to ensure that your data is protected against loss, alteration or unauthorised access by third parties; for this purpose, we use appropriate technical and organisational measures. The protection applies to information in a paper and a digital form. Your data can only be accessed by authorized employees and only for the listed purposes.

II. Data processing on our website:

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit our website. 

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this privacy policy.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to identify you. This privacy policy explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is being collected.

We herewith advise you that the transmission of data via Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.

Responsible party for the recording of data on this website (i.e. „controller“)

The data on this website is processed by the operator of the website, whose contact information is available under section „Imprint“ on this website.

How do we record your data?

We collect your data after you have shared it with us. This may, for instance be information you enter into our contact form.

Our IT systems automatically record other data when you visit our website. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access our website.

Purposes of processing

Some information is being generated to guarantee the error free functionality of the website. Other data may be used to analyse your user patterns.

Your rights in relation to the processing of your personal data

You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for this. You also have the right to demand that your data are rectified, blocked or erased. Please do not hesitate to contact us at any time under the address disclosed in section „Imprint“ on this website if you have questions regardding this or any other data protection related issues. You also have the right to lodge a complaint with the competent supervisory authority if you consider that the processing of your data violates Regulation (EU) 2016/679.

Moreover, under certain circumstances, you have the right to demand the restriction of the processing of your personal data. For details, please consult the section „Right to Restriction of Data Processing.“

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analysed when your visit our website. Such analyses are performed primarily with cookies and with what we refer to as analysis programmes. As a rule, the analyses of your browsing patterns are conducted anonymously; i.e. the browsing patterns cannot be traced back to you.

You have the option to object to such analyses or you can prevent their performance by not using certain tools. For detailed information about the tools and about your options to object, we refer to our privacy policy below.

Withdrawal of your consent to the processing of data

Some data processing operations are possible only based on your explicit consent. You can also withdraw at any time any consent you have already given us. To do so, you are required to sent us an informal notification via e-mail. The withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal.

Right to object to the collection of data in special cases; right to object to direct marketing (Art. 21 of Regulation (EU) 2016/679).

In the event that data are processed on the basis of Art. 6 para 1 lit. e) or f) of Regulation (EU) 2016/679, you have the right at any time to object to the processing of your personal data based on grounds relating to your particular situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this privacy policy. If you object, we will no longer process your affected personal data, unless we are in a position to demonstrate compelling protection worthy grounds for the processing it, that outweigh your interests, rights and freedoms or if the purpose of the processing is the establishment, exercise or defence of legal claims (objection pursuant to Art. 21 para. 1 of Regulation (EU) 2016/679).

If your personal data is being processed in order to engage in direct marketing, you have the right at any time to object to the processing of your affected personal data for the purposes of such marketing. This also applies to profiling to the extent that it is affiliated with such direct marketing. If you object, your personal data will subsequently no longer be used for direct marketing purposes (objection pursuant to Art. 21 para. 2 of Regulation (EU) 2016/679).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the of Regulation (EU) 2016/679, data subjects are entitled to lodge a complaint with a supervisory authority, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to lodge a complaint is in effect regardless of any other administrative or court proceedings available as legal remedies. 

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption programme. You can recognise an encrypted connection by checking whether the address line of the browser switches from „http://“ to „https://“ and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, blockage, rectification and erasure of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified, blocked or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section „Imprint.“

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section „Imprint.“ The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to establish, defend or exercise legal claims, you have the right to demand the restriction of the processing of your personal data instead of its erasure.
  • If you have raised an objection pursuant to Art. 21 para. 1 of Regulation (EU) 2016/679, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only based on your consent or to establish, exercise or defend legal claims or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in section „Imprint“ to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

Recording of data on our website:

Cookies

In some instances, our website and its pages use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. The purpose of cookies is to make our website more user friendly, effective and secure. Cookies are small text files that are placed on your computer and stored by your browser.

Most of the cookies we use are so-called „session cookies.“ They are being automatically deleted after your leave our site. Other cookies will remain archived on your device until you delete them. These cookies enable us to recognise your browser the next time you visit our website.

You can adjust the settings of your browser to make sure that you are notified every time cookies are placed and to enable you to accept cookies only in specific cases or to exclude the acceptance of cookies for specific situations or in general and to activate the automatic deletion of cookies when you close your browser. If you deactivate cookies, the functions of this website may be limited.

Cookies that are required for the performance of the electronic communications transaction or to provide certain functions you want to use (e.g. a shopping cart function etc.), are stored persuant to Art. 6 para. 1 lit. f) of Regulation (EU) 2016/679. The website operator has a legitimate interest in storing cookies to ensure the technically error free and optimised provision of the services. If other cookies (e.g. cookies for the analysis of your browsing patterns) should be stored, they are addressed separately in this privacy policy.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The host name of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources. This data is recorded on the basis of Art. 6 para. 1 lit. f) of Regulation (EU) 2016/679. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

Hence, the processing of the data entered into the contact form occurs exclusively based on your consent (Art. 6 para. 1 lit. a) of Regulation (EU) 2016/679). You have the right to withdraw at any time any consent you have already given us. To do so, you are required to sent us an informal notification via e-mail. The withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal.

The information you have entered into the contact form shall remain with us until you ask us to erase the data, withdraw your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have finished our response to your inquiry). This does not affect any mandatory legislation – in particular retention periods.

Request by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not transmit these data without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b) of Regulation (EU) 2016/679, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on your consent (Article 6 para. 1 lit. a) of Regulation (EU) 2016/679) and/or on our legitimate interests (Article 6 para. 1 lit. f) of Regulation (EU) 2016/679), since we have a legitimate interest in the effective processing of requests addressed to us.

The data sent by you to us via contact requests remain with us until you request us to delete it, withdraw your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular data retention periods required by law - remain unaffected.

Processing of data relating to clients and contracts

We collect, process and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 para. 1 lit. b) of Regulation (EU) 2016/679, which permits the processing of data for the fulfilment of a contract or pre-contractual measures. We collect, process and use personal data concerning the use of our website (usage data) only to the extent that this is necessary to make it possible for users to utilise the services, which they are billed for. 

The collected customer data are being erased upon completion of the order or the termination of the business relationship. This does not affect any data retention periods required by law.

Plugins und tools

Google Web Fonts (local embedding)

This website uses so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.

Google Maps

Via an API, this website uses the mapping service Google Maps. The provider is Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6 para. 1 lit. f) of Regulation (EU) 2016/679.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Use of EverCAPTCHA

To protect our contact form against unwanted use, we use the EverCAPTCHA service of our website creator and hoster. This service is provided by the sub-processor: wwwe GmbH, Hansaallee 299, 40549 Düsseldorf, Germany. EverCAPTCHA makes it possible to distinguish whether the data entered in the contact form was actually entered by a human or abusively automated by a machine, a so-called spambot.

For this purpose, various questions are asked when using our forms (e.g.: "Click on an X symbol", etc.). EverCAPTCHA saves all failed attempts by a user, an IP address via a session ID, which is stored in LocalStorage. The session ID is transmitted to the server via JavaScript with every request. If 30 incorrect entries have been made, the user's IP address is being permanently stored in a spam prevention database. Otherwise, the IP addresses will be deleted within 7 days.

Individual social networks

Facebook

We have a profile on Facebook. The provider is Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. Facebook is certified under the EU-US Privacy Shield.

You can customise your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads.

Details can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.

Facebook Fanpage Insights - Notice for our Facebook Fanpage users

Facebook Ireland Ltd. ("Facebook") provides us as a Facebook fan page operator with so-called "Facebook Insights" ("Insights"). The insights are various statistics that give us information about the use of our Facebook fan page. Detailed information on this and which data processing takes place can be found at https://www.facebook.com/business/a/page/page-insights as well https://www.facebook.com/legal/terms/information_about_page_insights_data

Facebook-Fanpage-Insights can be based on personal data that was recorded in connection with a visit or an interaction of people on or with our Facebook fan page and its content, so that personal data can also be processed by Facebook, visit our Facebook site. The essential information of the agreement concluded between us and Facebook within the meaning of Art. 26 of Regulation (EU) 2016/679 can be found there: https://www.facebook.com/legal/terms/page_controller_addendum

Regarding the Facebook-Fanpage Insights are jointly responsible for the processing:

Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour Dublin 2, Ireland https://www.facebook.com/business/gdpr https://www.facebook.com/help/contact/540977946302970

and

Iveka 2000 Ltd., 4199 Trud, Mestnost Gerena 62036, Plovdiv аrea, Bulgaria,

odrysia.apart@gmail.com.

Facebook Ireland primarily fulfils:

  • the information obligations from Articles 12 and 13 of Regulation (EU) 2016/679, and
  • the obligations from Articles 15 to 21 of Regulation (EU) 2016/679, the rights of the data subject can therefore be asserted against Facebook Ireland, as well
  • the obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

Of course, you can also assert your rights against us.

Facebook Ireland takes appropriate technical and organizational measures in accordance with Art. 32 of Regulation (EU) 2016/679 to ensure the security of processing through Facebook Fanpage Insights.

For the legal basis and purposes of processing by Facebook Ireland, please refer to the information here: https://www.facebook.com/about/privacy/legal_bases and https://www.facebook.com/policy.php

We process the Facebook Fanpage Insights data based on our legitimate interest in evaluating the activities on our fanpage and our marketing measures there (advertisements, campaigns, postings) persuant to Art. 6 para. 1 lit. f) of Regulation (EU) 2016/679.

Further information: Data protection: Facebook Fanpages and InSights - here are the answers.

You are not legally obliged to provide your personal data. However, the provision may be necessary for a contract or for functions of the Facebook fan page. If not provided, a contract or a function on the Facebook fan page may not be offered.

The rights of data subjects arise in particular from Articles 15 to 23 and Art. 77 of Regulation (EU) 2016/679.

With regard to your personal data, you have the right to

  • Access, Art. 15 of Regulation (EU) 2016/679
  • Correction, Art. 16 of Regulation (EU) 2016/679
  • Erasure, Art. 17 of Regulation (EU) 2016/679
  • Restriction of processing, Art. 18 of Regulation (EU) 2016/679 and
  • Transferability, Art. 20 of Regulation (EU) 2016/679.

You also have the right to object to the processing of personal data

  • Objection, Art. 21 of Regulation (EU) 2016/679

to be collected, see further information below separately.

If you have given your consent to the processing of personal data, you have the right of

  • Withdrawal, Art. 7 of Regulation (EU) 2016/679

with effect for the future.

Please direct all inquiries, requests and notifications to Facebook Ireland or to us, see above.

If you believe that the processing of your personal data violates Regulation (EU) 2016/679, you always have the

  • Right to lodge a complaint

at the responsible supervisory authority (persuant to Art. 77 of Regulation (EU) 2016/679). Without prejudice to any other administrative or judicial remedies, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data violates Regulation (EU) 2016/679. The supervisory authority responsible for Facebook Ireland is the Irish Data Protection Commission (https://www.dataprotection.ie/).

INFORMATION ABOUT YOUR RIGHT TO OBJECT UNDER ART. 21 of Regulation (EU) 2016/679

1. You have the right to object to the processing of your personal data at any time, on grounds relating to your particular situation, based on Art. 6 para. 1 lit f) of Regulation (EU) 2016/679 (data processing based on a legitimate interests).

If you file an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.

2. In individual cases, we process personal data in order to operate direct mail. If this is the case for you, you have the right to object at any time to the processing of your data for the purpose of such advertising.

If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes. The objection can be made without using a form.

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