Personal data
This privacy policy, in compliance with the awareness requirements under Art. 13 and Art. 14 of the General Data Protection Regulation (GDPR), aims to inform you about the personal data processing activities carried out by Saints Constantine and Helena Holding AD, the purposes for which the data are processed, the measures and the guarantees for the protection of the data being processed, your rights and the way you can exercise them in accordance with the requirements of EU Regulation 2016/679 of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. Therefore, please get acquainted with the contents of the policy by reading it carefully. Should you have any questions, you can ask them at the following e-mail address: gdpr@stconstantine.bg.
Data Controller contact details:
Saints Constantine and Helena Holding AD, hereinafter referred to as "the Company", is a legal entity registered in the Commercial Register and the Register of Non-Profit Legal Entities at the Registry Agency with UIC 813194292, with its registered office and business address at: Saints Constantine and Helena resort, Administrative Building, Varna, represented by Elena Koseva and Ivelina Shaban in their capacity as executive directors.
Saints Constantine and Helena Holding AD is a Controller of the personal data that are processed during or in connection with the implementation of the powers conferred to it by Regulation 2016/679 and the Law on the Protection of Personal Data.
Definitions
For the purposes of this policy:
Personal data is any information relating to an individual who is identified or can be identified directly or indirectly by an identification number or by one or more specific features. The data may relate to facts (for example - name, e-mail address, location or date of birth) or to an opinion on the data subject's actions or behavior.
A Personal Data Administrator is a natural or legal person, public body, agency or other entity which, alone or jointly with others, defines the purposes and means of processing personal data; where the purposes and means of such processing are determined by a Union or Member State’s law, the controller or the specific criteria for its determination may be established in the Union law or in the law of the Member State;
Processing of personal data is any action or set of actions that may be performed on personal data by automatic or other means, such as collecting, recording, organizing, storing, adapting or modifying, restoring, consulting, using, disclosing by transmission, disseminating, providing, updating or combining, blocking, deleting or destroying.
Direct marketing is a set of activities aimed at improving the quality of our services and matching them with the exact needs and interests of our guests, as well as an analysis of their satisfaction. This includes activities such as online advertising campaigns, e-mail marketing, surveys, user profiling, etc.
Processing of personal data
In order to secure and improve our services and resource management needs, we store, use and process personal data while complying with the applicable legal requirements.
Purposes and grounds for processing of personal data, categories of data processed.
In order to secure and improve our services and resource management needs, we store, use and process personal data while complying with the applicable legal requirements.
For direct marketing purposes, including analyzing and profiling target audiences and tracking the satisfaction of our customers, we process the following data:
- E-mail address
- IP address
- Location
- Language
- Age
- Gender
- Interests
- Behavior of the users at the site www.stconstantine.bg
The data subject's consent is explicitly required for the processing and storage of these data. Data processed for direct marketing purposes is kept for 26 (twenty-six) months or until consent is withdrawn. The purpose of collecting this data is to provide you with personalized offers and services tailored to your needs and expectations.
Principles of processing
When processing personal data, we comply with the following principles: Legality: in collecting, processing and storing your data, we comply with the applicable Bulgarian and European legislation;
Good faith and transparency: we collect and process the data in accordance with the current privacy policy which is available to each user;
Relevance of processing to objectives and minimization of data: the types of data we collect are minimized in line 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 received data for a period of time, according to the purposes for which it is needed and subject to your consent. User consent for data processing: in order to use your data for marketing purposes, for the purpose of improving the services that we provide to you, we must obtain your explicit consent to that effect.
Electronic (E-mail) newsletter and direct advertising
Please keep in mind that when you send an enquiry through the website www.stconstantine.bg, you give your consent to Saints Constantine and Helena Holding AD to store and process the personal data provided by you for the purpose of the inquiry sent.
After sending your inquiry, you will receive from Saints Constantine and Helena Holding AD a request to give your consent to process your data for the following purposes:
- for direct marketing purposes, as well as receiving newsletters about our current offers of travel ideas and organized games and events;
- for surveys, about your satisfaction with our services;
With our e-newsletter, we regularly inform you about the offers and services offered in hotels and other leisure facilities on the resort's premises. By agreeing to process your data for direct marketing purposes, you will not only receive up-to-date information about our most attractive offers, but you will also contribute to improving our services. By agreeing, you will enable us to provide you with information on 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 would like to receive the newsletter, we will need a valid e-mail address. For those who sign up for our newsletter, we use the so-called Double Inclusion procedure. This means that after your registration, we will send you an email at the e-mail address in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 2 weeks, your information will be blocked and will automatically be deleted after one month. In addition, in each case we store the IP addresses used and the time of login and confirmation. The purpose of the procedure is to be able to prove your registration and where necessary to clarify any potential misuse of your personal data.
As a subscriber to the newsletter, you may at any time withdraw your consent to the processing of your e-mail address for the purpose of sending you the newsletter. Your consent can be canceled via the link provided for this purpose in every e-mail newsletter or by sending an e mail with title "unsubscribe" title to gdpr@stconstantine.bg.
Rights of data subjects
The measures taken to protect personal data in accordance with the requirements of Regulation 2016/679 are aimed at ensuring the rights of the individuals whose personal data are processed, namely:
Right of access. By a written request, you can obtain information about the type of personal data provided and the purpose of their processing. The request may be filed personally at the specified contact address or electronically from the e-mail address you provided to us as processing details to gdpr@stconstantine.bg under the terms of the Electronic Document and Electronic Certification Services Act, the E-government Act and the Electronic Identification Act. Your application must contain full name, UCN, address for correspondence, description of the specific request, and a preferred form for obtaining information when exercising your rights, signature, date of filing the request.
Right to correct inaccurate or incomplete data. By gaining accessing to your data, you can ask for them to be corrected in case you find errors or discrepancies.
Right to erasure (right to be forgotten). Where the conditions of Art. 17 of Regulation 2016 / 679 apply, following access to your personal data you may require to remove any records of your personal information without the possibility of further processing;
Data portability. Consumers have the right to receive their data, which Saints Constantine and Helena Holding AD stores when they are provided in a structured, widely used and machine-readable format. Consumers are also entitled to transfer this data to another data controller without hindrance by Saints Constantine and Helena Holding AD in the cases and with regard to the data provided by consent, in the cases of data provided under a contract to which the consumer is a party or data provided following steps taken by the consumer and a request for the conclusion of a contract.
Right of objection. Users have the right to object to the processing of their data. Such objection shall be directed to Saints Constantine and Helena Holding AD, under the order of obtaining access to personal data. Saints Constantine and Helena Holding AD undertakes to examine your objection and to inform you about the outcome of the internal review within 30 calendar days of its receipt.
Right to limited processing within the meaning of Article 18 of Regulation 2016/679.
Right of the data subject not to be the subject of a decision based solely on automated processing, involving profiling.
Right to appeal to the Commission for the Protection of Personal Data or to the Court.
If you believe that your rights under Regulation 2016/679 have been violated, you may file a complaint with the Personal Data Protection
Commission or the Administrative Court of Varna
Protection of personal data
Privacy of personal data
We use electronic methods for processing personal data to ensure accurate and fast service delivery and user assistance.
The process of processing your personal data provided to Saints Constantine and Helena Holding AD is carried out in accordance with the applicable data protection legislation and Saints Constantine and Helena Holding AD respects your privacy.
Individualization and cookies
New technologies enable us to customize our website for each individual customer. 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: www.stconstantine.bg and do not cause any harm to your system. Cookies relieve you of the need to enter data more than once, facilitate the transmission of specific content, and help identify your preferences (viewability and usability settings). Accumulating and analyzing this information allows us to improve our e-services and overall user experience so that they fit as closely as possible to your needs. About cookies and other technologies that we use, you can learn from our Cookies Policy.
Personal data security
Saints Constantine and Helena Holding AD applies technical and organizational security measures in order to protect the personal data you have provided from accidental or unlawful destruction, accidental loss, unauthorized access, alteration or dissemination, as well as other illegal forms of processing by unauthorized persons. The security measures we apply are subject to constant improvement and adaptation to state-of-the-art technologies.
Collected personal data may be provided to partners of Saints Constantine and Helena Holding AD who act as personal data processors on behalf of Saints Constantine and Helena Holding AD and are committed to comply with all applicable norms for the protection of personal data. We comply with the condition that the relevant information may only be used within the limits set by the legal basis on which it is collected or by your personal consent regarding the processing performed on behalf of Saints Constantine and Helena Holding AD, and that this information should be treated as confidential.
Saints Constantine and Helena Holding AD may disclose and provide personal information in accordance with the applicable law if a court or administrative authority orders or requests it or if the provision of personal data is related to the fulfillment of a legal obligation of Saints Constantine and Helena Holding AD.
Changes to personal data protection rules
The rules for the protection of personal data can be changed unilaterally by Saints Constantine and Helena Holding AD with a view to their improvement, offering new services, changes in the way of servicing and communicating with our customers, as well as in relation to legislative changes.
When making changes to the current rules for the protection of personal data, Saints Constantine and Helena Holding AD brings to your knowledge the changes made by publishing them on our website www.stconstantine.bg, giving you a reasonable time to get acquainted with them, after the expiration of which, the new rules for the processing of your personal information will begin to apply without further notice. If within this period you declare that you are rejecting the changes, you will be deemed to have withdrawn your consent to the processing of your personal data, and Saints Constantine and Helena Holding AD will cease their processing in the future. This may also involve terminating your registrations for our games, services, newsletters, etc. for the purposes of which you have originally provided us with your personal data.
If you have any questions regarding our measures and rules for personal data protection at Saints Constantine and Helena Holding AD, please contact the Saints Constantine and Helena Holding AD team by sending a message to the following address: Saints Constantine and Helena Holding AD - Protection of personal data: gdpr@stconstantine.bg.