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PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA

The policy of Marina Sands Ltd. is aimed at ensuring compliance with the provisions of the Regulation (GDPR).

Marina Sands Ltd. collects and processes personal data lawfully, fairly, and in accordance with the principles and rights of individuals concerning the processing of their personal data.

Marina Sands Ltd. processes personal data of individuals only in the following cases:

  • The processing is necessary for compliance with a legal obligation of Marina Sands Ltd.;
  • The processing is necessary for the performance of a contract (including an order) to which the individual is a party, or to take steps at the request of the individual prior to entering into a contract when identification is required;
  • The individual has given their explicit consent for a clearly defined and transparent purpose, for which Marina Sands Ltd. needs to process their personal data;
  • 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 Marina Sands Ltd. or by a third party, in accordance with the provisions of the Regulation;
  • Other cases as provided for in the Regulation.

Marina Sands Ltd. does not collect or process personal data of individuals beyond what is required by law or necessary for conducting its business activities.

In all cases where it is necessary to use collected and processed personal data for purposes other than those originally intended, Marina Sands Ltd. informs the respective individuals, requests their consent, and proceeds with the processing of their data for the new purposes only after receiving their explicit approval.

Marina Sands Ltd. collects and processes only the minimum necessary personal data of individuals that:

  • Are required by law;
  • Are necessary for the performance of a contract;
  • Are necessary to achieve the purposes for which the data is collected.

Marina Sands Ltd. ensures that personal data is processed with the highest possible accuracy and, where possible, kept up to date.

The company also ensures that access to and processing of personal data is carried out by the minimum number of authorized individuals (operators) necessary, who possess the required competence and are committed to protecting the data.

DATA RETENTION PERIODS

Marina Sands Ltd. retains personal data for the following periods:

Guest Register Data under Article 116 of the Tourism Act, which includes identification data of accommodated persons and hotel accommodation details – retained in accordance with the procedures and timeframes set out in the Tourism Act and related regulations.

Information related to requested and used services, such as hotel accommodation, events, and restaurant services, including cancelled reservations (insofar as they involve refunding prepaid amounts and/or withholding due amounts) – retained from the time of the reservation/request until five (5) years after the service has been provided / the contract has been completed / or the reservation has been cancelled. For services under long-term contracts, the retention period starts from the date of final fulfillment or contract termination.

Financial and accounting documents (e.g., invoices, authorization forms, and other information relevant to tax and social security control) – retained for up to ten (10) years, counted from the beginning of the year following the year in which the liability was due.

Unstructured communication, such as correspondence, complaints, alerts, and similar – retained for five (5) years.

Video surveillance data – retained for up to one (1) week.

Data processed based on the data subject’s explicit consent – retained from the moment consent is given until it is withdrawn by the data subject.

Upon request by the individual for deletion, if there are legal grounds for such a request.

The personal data specified in this Policy may be retained for a longer period than those listed above if this is necessary to achieve the purposes outlined herein or to protect the rights and/or legitimate interests (including through legal proceedings) of Marina Sands Ltd., or if applicable law requires data retention for a longer period.

In all cases, Marina Sands Ltd. ensures that a review of collected and processed personal data is carried out at least once per year, and any data falling under the conditions mentioned above is deleted without undue delay.

RULES FOR PERSONAL DATA PROCESSING

Personal data is processed with the necessary levels and measures of protection.

Marina Sands Ltd. ensures the required levels of physical, organizational, and technological security, taking into account:

  • The nature, scope, context, and purpose of the personal data being processed;
  • The likelihood, severity, and impact of risks to the rights and freedoms of individuals in the event of a data security breach;
  • Its financial and organizational capacity.

Marina Sands Ltd. also provides all necessary measures for the timely recovery of collected and processed personal data in the event of loss due to accidental, malicious, or force majeure events.

Personal data is processed with controlled and traceable access.

Marina Sands Ltd. implements the necessary and appropriate technical, organizational, and technological measures to ensure controlled and traceable access to individuals’ personal data.

Personal data is processed with accountability to ensure compliance with the Regulation.

Marina Sands Ltd. maintains the required records and documentation to demonstrate compliance with the provisions of the Regulation.

DATA SUBJECTS

In connection with the services provided, Marina Sands Ltd. processes information related to the following categories of data subjects:

  • Individuals visiting the hotel’s website;
  • Individuals making reservations on their own behalf or on behalf of another natural or legal person through the website;
  • Individuals using the services provided by Marina Sands Ltd., including but not limited to hotel accommodation, restaurant services, related hospitality services, rental of event venues, as well as individuals representing or acting on behalf of legal entities using these services.

The services of Marina Sands Ltd. may only be requested by legally competent persons who are at least 18 years of age.

RIGHTS OF INDIVIDUALS WHOSE DATA IS PROCESSED

Marina Sands Ltd. ensures the protection of 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 – to know what data is being held;
  • the right to rectification of inaccurate personal data;
  • the right to erasure of personal data – the “right to be forgotten”;
  • the right to restrict the processing of personal data;
  • the right to be informed about actions taken in response to a request for rectification, erasure, or restriction of processing;
  • 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.

PERSONAL DATA PROCESSED

Personal Data Processed in the Capacity of Data Controller:

  • of employees;
  • of individual (natural person) clients;
  • of individual (natural person) suppliers.

PURPOSES FOR PROCESSING PERSONAL DATA

As a Data Controller, Marina Sands Ltd. performs the following operations and processes only the personal data necessary for the following purposes:

  • to conclude, execute, and terminate employment contracts, and to calculate employee salaries and compensations;
  • to receive, manage, and process reservations and cancellations;
  • to manage, fulfill, and deliver purchases made through the website;
  • to manage and process payments for provided services, including remote payments;
  • to provide customer services;
  • to ensure a personalized approach in service delivery, tailored to users’ stated preferences;
  • to conclude and execute contracts with individual (natural person) suppliers;
  • for direct marketing purposes related to sales.

RECIPIENTS AND CATEGORIES OF RECIPIENTS

In connection with fulfilling the above-mentioned purposes, Marina Sands Ltd. provides personal data to the following recipients:

  • the National Revenue Agency (NRA), for calculating staff salaries;
  • the National Social Security Institute (NSSI), for calculating employee compensations;
  • occupational health service providers, for maintaining up-to-date employee health status and conducting periodic medical check-ups;
  • the General Labour Inspectorate, NSSI, and the Ministry of Interior – in relation to workplace accidents;
  • the Ministry of Interior – for transmitting guest information for hotel check-in registration;
  • other state or municipal authorities and/or institutions – in connection with legal obligations or lawful requests requiring the provision of personal data;
  • subcontractors for the performance of contractual obligations.

VIDEO SURVEILLANCE AND SECURITY

In accordance with the applicable legislation, Marina Sands Ltd. implements security measures, which include the following technical and organizational means for access control and physical protection of its buildings and premises, as well as for the safety and well-being of individuals: a video surveillance system operating 24/7, consisting of recording and storage devices.

Video surveillance and recording may be conducted in publicly accessible areas and premises within the buildings of Marina Sands Ltd., as well as in areas subject to restricted access. Video surveillance is not conducted in guest rooms, restrooms, relaxation areas, or similar premises. Data collected through video surveillance activities is retained for a period of seven days.

Data subjects and other visitors who may be recorded are informed of the use of surveillance and monitoring equipment, as well as any other relevant information related to the surveillance, through informational signs placed in clearly visible locations.

Processing of Personal Data for Marketing Purposes

We collect and process personal data for marketing purposes in order to provide personalized offers, news, and promotions that may be of interest to you. This includes sending marketing communications via email, SMS, phone calls, or other communication channels.

Categories of Personal Data

The personal data processed may include:

First and last name

Email address

Phone number

Legal basis for processing:

The processing of personal data for marketing purposes is carried out based on your explicit consent. You have the right to withdraw your consent at any time by contacting us or using the unsubscribe option included in every marketing message.

Data retention period:

Personal data will be stored until you withdraw your consent or until the expiration of the legally prescribed retention period.

Your Rights

You have the right to access, rectify, erase, restrict the processing of, and object to the processing of your personal data, as well as the right to data portability. For more information, please contact us.

CONTACT DETAILS OF THE COMPANY

If you have any questions or concerns regarding the processing of your personal data, or if you wish to exercise any of your rights, you can contact us at:

Email: marinasands1@gmail.com

Phone: +359 899 344 004

Address: Kavak Dere Area, Obzor, Bulgaria

COMPETENT SUPERVISORY AUTHORITY

Within the territory of the Republic of Bulgaria, the competent supervisory authority is the Commission for Personal Data Protection.

If you believe your personal data protection rights have been violated, you may file a complaint with:

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Email: kzld@cpdp.bg

Phone: +359 2 91-53-518

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Marina Sands