The Policy is drafted in compliance with the requirements under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 (the Regulation).
Art. 1. In connection with the provision of its services and performance of its activities, "Real Advance" Ltd., in its capacity as data controller, processes personal data of its customers – natural persons, as well as personal data of other individuals specified below (“Data Subjects”/ “you”), in compliance with the rules and principles under the present Policy.
Art. 2. "Real Advance" Ltd., UIC 203156490, with headquarters and management address: Burgas ; "Tsar Ivan Shishman" 39, with e-mail address email@example.com , tel. : 0894488551, represented by Rossitsa Georgieva – manager. The company is a Holiday Property Manager and Tour Operator under Registration number: РК-01-7709.
Art. 3. (1) In connection with the provided services "Real Advance" Ltd. processes information regarding the following Data Subjects:
(a) Individuals visiting the website www.poseidon-bg.com (Website)
(b) Individual persons who make reservations in their own name or on behalf of another individual or legal person through the on-line booking system on the Website owned by “Reseliva” Tophane, Bogazkesen Cad. 23/1, Beyoglu - Istanbul / Turkey, Phone number: +90 212 293 56 78 (09: 00-18: 30 GMT + 3); +90 212 252 73 63.persons making reservations through the Website, in their name or on behalf of another person or legal entity;
(c) Individuals or legal entity who make reservations in their own name or on behalf of another individual through Online booking systems Booking.com, Hotels.com, and similar.
(d) Individuals using the services provided by "Real Advance" Ltd., including, but not limited to, hotel accommodation, restaurant and related services, provision of conference and event halls, etc., as well as persons representing or acting in another manner on behalf of legal persons using the said services;
(e) Individuals who have made in their own name or on behalf of another person they represent, inquiries by e-mail, by calling or by filling in the contact form of the Website, using the Free Call functionality on the Website, etc.), requests, alerts , complaints, or other correspondence to Real Advance Ltd.
Personal data categories
Art. 4. The information (categories of personal data) concerning Data Subjects which is processed by "Real Advance" Ltd. pursuant to the present Policy may include:
1. In connection with the provision of hotel accommodation services:
(a) Identification data: guest’s full name; date of birth; gender; nationality; national identification number (such as PIN for Bulgarian citizens) and/or ID document number; ID document date of issue; ID document date of expiry; country issuing the ID document; signature.
(b) Contact details: telephone number; email address; address.
(c) Information related to hotel accommodation: room number; floor; dates of stay (check-in date, check-out date); duration of stay (number of nights spent at the hotel); tourist package, if used; type of room preferences (smokers/non-smokers);
(d) Additional information related to hotel accommodation at the customer’s explicit request: special requirements and preferences, special requirements related to food products and drinks
2. Data relating to payments and issuance of invoices: information regarding the payment method (in cash, by bank transfer, by credit card, etc.); information regarding due and effected payments; information regarding the due date of payment and overdue/outstanding debts; bank details (bank, IBAN, account holder); currency of the payment; number, expiry date and holder of the credit/ debit card; CVC code; data contained in the payment authorization slip; name of the legal person; address of the legal person; VAT number and/or other identification, tax or registration number (PIN for natural persons); authorization slips (signed).
3. In connection with the provision of restaurant services as a mediator between the dining venue and the client, mainly in organizing events:
(a) Identification data: full name.
(b) Contact details: telephone number; email address; address.
(c) Data relating to payments and issuance of invoices: number, expiry date and holder of the credit/debit card; CVC code; name of the legal person; address of the legal person; VAT number and/or other tax or registration number ; authorization slips (signed).
(d) Information of preferences (at the customer’s explicit request): food and drink preferences; preferred payment method; specific requirements related to food products, drinks and other substances which should be avoided by the guest (regardless of the reason).
4. In cases where the Data Subject represents another person (e.g. a company): information regarding the represented person and the capacity of the representative (incl. workplace, position), as well as information of ordered services/ submitted orders in such capacity. Respectively, in cases where the services are ordered by a person other than the Data Subject on behalf of the Data Subject – in what capacity the Data Subject will use the services, who has ordered the services, who will make the payment, etc. (for instance, in case of accommodations organized by an employer or a business partner of the Data Subject, etc.).
5. In connection with the services and functionalities of the Website:
(a) Data processed in connection with accommodation booking: full name, email address; telephone number; country; number, expiry date and holder of the credit/ debit card; CVC code; number of rooms; number of guests, including number of adults and number of children; corporate code/ access code; code of the participant in an event and/or group accommodation; booking number; special offers and preferences (with explicit indication in the booking form);
(b) non-structured content from conversations with and inquiries to a booking agent through the Free Call functionality on the Website.
(c) in connection with customer complaints, requests and alerts: information contained in the relevant complaints, , requests and alerts.
Art. 5. (1) Subject to the Data Subject’s explicit consent, "Real Advance" Ltd., respectively other companies related to or partners of "Real Advance" Ltd., may process the following personal data: names; telephone number; address; email address; information of the type and number of used and preferred services provided by "Real Advance" Ltd., and other data explicitly specified in the respective consent for the purposes of direct marketing, such as offering of goods and services, including goods and/or services offered by other persons, conducting inquiries and polls for the purpose of improving the quality of the services provided, etc., within the scope of the respective consent.
(2) Where personal data are processed for direct marketing purposes, the Data Subject shall be entitled at any time to object to such processing. In such cases, the processing of personal data for such purposes is terminated.
(3) The Data Subject shall be entitled at any time to withdraw his/her consent to the processing of his/her personal data for direct marketing purposes. In such cases, the personal data processing based on that consent is terminated.
Purposes of personal data processing
Art. 6. "Real Advance" Ltd. collects, stores, and processes the information described in Art. 4, 5, and above for the purposes provided for in the present Policy and in the General Terms (the contract) for use of the services provided. Depending on the legal grounds for the processing, those purposes may be:
(a) purposes related to the compliance with legal obligations of "Real Advance" Ltd.;
(b) purposes related to and/or necessary for the performance of the contracts concluded with "Real Advance" Ltd. or for taking steps at the request of the Data Subject prior to entering into a contract;
(c) purposes related to the legitimate interest of "Real Advance" Ltd. and third parties;
(d) purposes for which the Data Subject has given his/her consent to the processing of his/her data.
Art. 7. The purposes of personal data processing carried out by "Real Advance" Ltd. related to the compliance with legal requirements include:
1. keeping a register of accommodated guests and providing information from that register to the competent authorities, as legally required;
2. deduction and payment of tourist tax;
3. handling of signals, complaints, including preparation of the relevant replies thereto;
4. bookkeeping, invoicing and accounting of incoming and outgoing payments in compliance with the applicable tax and accountancy legislation;
5. other activities related to the fulfillment of "Real Advance" Ltd.’ legal obligations requiring the provision of information to and cooperation with the competent state and judicial authorities upon performance of inspections.
Art. 8. The purposes of personal data processing carried out by "Real Advance" Ltd. related to and/or necessary for the performance of contracts or for taking steps at the request of the Data Subject prior to entering into a contract with "Real Advance" Ltd. include:
1. receipt, administration and processing of bookings, including cancelled bookings;
2. customer services, including provision of online services through the Website;
3. communication related to the provision of services;
4. administration and receipt of payments for the services provided, including remotely;
5. ensuring a guarantee for bookings and payments of hotel accommodation and any extra services requested;
6. processing and collection of payments due for the services provided and invoicing;
7. refunding of incorrectly transferred amounts;
8. ensuring an individual approach in the provision of the services, taking account of the explicitly specified preferences of the customer.
Art. 9. The purposes related to the legitimate interests of "Real Advance" Ltd. and third parties include:
1. Legitimate interest – exercise and protection of the rights and legitimate interests of "Real Advance" Ltd.; and assistance in the exercise and protection of the rights and legitimate interests of customers; of other persons related to "Real Advance" Ltd.; of employees of "Real Advance" Ltd.; of data processors processing personal data on behalf of "Real Advance" Ltd.; and of business partners of "Real Advance" Ltd.:
(a) establishment, exercise or defense of legal claims of the persons specified above under items and , including by legal proceedings and filing of complaints, signals, etc. with the competent state and judicial authorities;
(b) taking actions for suspending the services provision in case of refusal of payment, violations of "Real Advance" Ltd. established rules and policies, etc.;
(c) administration and handling of submitted complaints, signals, requests, etc.;
2. Analysis, planning and improving the quality of services provided by "Real Advance" Ltd.:
(a) keeping a backup copy of the data in the internal information system regarding the current state of the hotel (occupation/ availability of rooms, obligations, etc.) in case of information systems failure;
(b) survey of the customers’ satisfaction with the services; receive feedback on the services provided.
(c) control, analysis, and optimization of the business processes for improvement of the quality of services.
3. Ensuring the normal functioning and use, maintenance and administration of the Website;
Art. 10. The purposes of personal data processing based on consent given by the Data Subject include:
1. Sending marketing and advertising communications regarding services, exclusive offers, packages, events, etc.
2. Surveys and receiving feedback on the quality of services;
3. Sending newsletters;
4. Other purposes for which the Data Subject has explicitly given his/her consent.
Provision of personal data and consequences from refusal to provide such data to "Real Advance" Ltd.
Art. 11. (1) "Real Advance" Ltd. clearly indicates, where applicable and in the appropriate manner, whether the provision of the respective data and/ or documents is mandatory or constitutes a requirement necessary for the conclusion or performance of a contract, as well as the consequences from the refusal to provide such data.
(2) If needed, any Data Subject may request further clarifications at the premises of "Real Advance" Ltd. or by addressing respective query to the contact details specified in Art. 20 of the present Policy.
(3) Any refusal to provide data and documents indicated as mandatory may prove an impediment to the provision of a service by "Real Advance" Ltd., to the satisfaction and execution of submitted requests, applications, signals, etc., which releases "Real Advance" Ltd. from liability for default.
(4) Any refusal to provide data and documents or any provision of false data may entail failure to provide the respective services or suspension of the access to services provided "Real Advance" Ltd.
(5) Data Subjects shall not provide "Real Advance" Ltd. with any special categories of data within the meaning of Art. 9 and Art. 10 of the Regulation (namely: personal data revealing racial or ethnic origin, political opinion, religion or philosophical beliefs, trade union membership, genetic data, biometric data, health status, or sexual life or orientation of the natural person; and personal data related to criminal convictions and offences).
Other sources of personal data
Art. 12. (1) In certain cases, the personal data processed by "Real Advance" Ltd. are not collected and received directly from the Data Subject of the relevant data, but from third parties, such as:
1. Persons representing, working for or otherwise cooperating with the Data Subject;
2. Event organizers – with respect to information concerning the participants in the event;
3. Business partners (e.g. booking sites as booking.com; tourist agencies, other persons that provide intermediary services in the context of booking or ordering of other services, etc.) of "Real Advance" Ltd.;
4. Competent state and judicial authorities.
(2) The persons under Para. 1, item 1-3 shall inform the Data Subjects whose data they provide to and to ensure that they provide data based on a valid legal basis.
Processing of information by third parties – data processors
Art. 13. (1) For the purposes specified in the present Policy, "Real Advance" Ltd. may assign data processing activities to third parties – data processors, in compliance with the requirements under the Regulation and the other applicable personal data protection rules.
(2) Where personal data are disclosed to and processed by data processors, such disclosure and processing will be carried out only to the extent and in the amount necessary for the performance of the tasks assigned by "Real Advance" Ltd..
(3) Data processors act on behalf of "Real Advance" Ltd. and are obliged to process personal data only in strict compliance with "Real Advance" Ltd. instructions. Data processors shall not be entitled to use or otherwise process the information for purposes other than for the purposes specified in the present Policy.
Categories of recipients of personal data
Art. 14. "Real Advance" Ltd. does not disclose personal data concerning the Data Subject to third parties except where:
1. This is necessary for compliance with a legal obligation of "Real Advance" OOD to competent state, municipal or judicial authorities;
(a) data processors as assigned by "Real Advance" Ltd.;
3. this is necessary for the provision of the services of "Real Advance" Ltd.:
(a) banks and payment services providers;
(b) postal and delivery services providers;
(c) "Real Advance" Ltd.business partners such as: booking sites; travel agencies and other providers of tourist services or other supportive services such as car rental, taxi and other transport services, etc.
4. The Data Subject has given his/her explicit consent – the persons provided for in the relevant consent (e.g. "Real Advance" Ltd. related parties, "Real Advance" Ltd. business partners, etc.);
5. this is necessary to protect the rights and legitimate interests of "Real Advance" Ltd., third parties or Data Subject: state, municipal and judicial authorities; lawyers; notaries public.
6. in other cases provided by law.
Art. 15. (1) "Real Advance" Ltd. processes and stores information about the Data Subject until achieving the relevant purposes it is collected and processed for.
(2) "Real Advance" Ltd., in accordance with its internal rules and procedures, as well as the applicable legislation, processes and stores information about the Data Subject for the periods as follows:
Type of data and Storage period:
A) Data relating to the register for accommodated tourists within the meaning of Art. 116 of the Tourism Act, including identification data of the accommodated persons as well as data related to the hotel accommodation
· In accordance with the procedures and time limits stipulated in the Tourism Act and the relevant regulations
B) Information relating to requested and used hotel accommodation services, events and restaurant services, including such relating to cancellation of bookings for hotel accommodation (as far as they involve a refund of pre-paid amounts and/or a deduction of amounts due)
· From making the respective booking/ request up to 5 /five/ years from the provision of the service/ completion of the contract/ cancellation of the booking.In cases where the services are requested and used based on a long-term contract, the period starts running from the complete performance and/ or termination of the contract.
C) Financial and accounting documents; invoices; authorization slips; other information related to tax and insurance control.
· Up to 10 /ten/ years from the beginning of the year following the one in which payment of the amount for the relevant year is due.
D) Unstructured communication, correspondence, complaints, signals, etc.
· 5 years. In cases where the correspondence concerns a long-term contract, the period starts running from the complete performance and/ or termination of the contract.
E) Data processed based on the explicit consent of the Data subject
• From the moment the consent is given to its withdrawal from the Data subject.
The personal data referred to in this Policy may also be processed for a longer period than the ones specified above if this is necessary to achieve the objectives set forth therein or to protect the rights and/or legitimate interests (including in legal proceedings) of "Real Advance" Ltd. or if the current legislation provides for data processing for a longer period.
Rights of the Data Subjects regarding their personal data
Art. 16. (1) In relation to the processing of the personal data concerning him/her, each Data Subject has the following rights:
1. Right of information – to be provided with information on the processing of his/her personal data from "Real Advance" Ltd.;
2. Right of access:
(a) to obtain confirmation as to whether personal data concerning him/her are being processed;
(b) to have access to the processed personal data and detailed information about its processing and his/her rights.
3. Right of rectification – to require his/her personal data to be rectified and completed if the data are inaccurate or incomplete;
4. Right of erasure – to require his/her personal data to be erased;
5. Right of restriction of personal data processing – to require that "Real Advance" Ltd. restricts the processing of his/her personal data within the limits provided for the Regulation if there are the grounds for this set forth therein;
6. Right to notify third parties – to require that "Real Advance" Ltd. notifies the third parties to whom his/her personal data have been disclosed of any rectification, erasure or restriction of the processing of his/her personal data unless this proves impossible or involves disproportionate effort from "Real Advance" Ltd.;
7. Right of withdrawal of consent to processing - when the processing of personal data is based only on consent given by the data subject, the latter may withdraw its consent at any time.
Right to object
Art. 17. The Data Subject shall have the right to object, on grounds relating to his/her particular situation, at any time to processing of personal data concerning him/her, including profiling within the meaning of the Regulation, based on public interest, exercise of official authority and the legitimate interests of "Real Advance" Ltd. or a third party. In these cases, "Real Advance" Ltd. shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or where necessary for establishing, exercising or defending legal claims.
Art. 19. (1) The Data Subject may exercise his/her personal data protection rights by personally submitting a written request at the address specified in Art. 23 of this Policy or by sending a notary certified request by post.
(2) The request under Para 1 may also be exercised via electronic means, and for this purpose the same shall be signed by the Data Subject with a qualified electronic signature within the meaning of the Electronic Document and Electronic Certification Services Act and Art. 3 (12) of Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC; which is to be sent to "Real Advance" Ltd. at the electronic address referred to in Art. 23 of this Policy.
(3) The Data Subject may exercise the rights relating to his/her personal data either personally or through an explicitly authorised person (with a power of attorney certified by a notary).
(4) Part of the rights may also be exercised through the functionalities available on the Website.
Right to lodge a complaint with a supervisory authority
Art. 19. Any Data subject has the right to lodge a complaint with a Data Protection Supervisor if he considers that the processing of his or her personal data violates the provisions of the Regulation or other applicable data protection requirements.
Art. 20. Supervisory authority in the Republic of Bulgaria is:
Commission for Personal Data Protection
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
Art. 21. The Data Subject may seek clarifications regarding the content, the grounds and the way of exercising his/her rights under this Policy, as well as any additional information regarding his/her rights regarding the processing of personal data by "Real Advance" Ltd. on the following contacts:
Address: Burgas ; "Tsar Ivan Shishman" 39.
Telephone: +359894488550 ; +359894488551