PRIVACY POLICY admin December 20, 2022


Klasman Enterprises Ltd., Burgas

Regarding   the website and the shops  of the hotel complex “Longoza”, k.k. Sunny Beach, according to REGULATION (EU) 2016/679 on the processing and protection of personal data

This policy is an integral part of the General Terms of Use of the site.
For questions or comments regarding the  Privacy Policy, you can find contact information on the contact page.
Please read this Policy carefully before using our services.

Important to know:

  • By registering on our platform, you agree to the Privacy Policy and expressly confirm your acceptance of it.
  • If you do not want us to process your personal data in the manner described in the Policy, please do not provide them. The provision of Personal Data is voluntary, with a view to using or accessing our services. Any refusal by you to provide the necessary personal data would mean a refusal to use the relevant services and to access them.
  • Your express consent to the processing of personal data may not be necessary if another legal basis is available such as: compliance with the Administrator’s legal obligations; necessity for the performance of a contract and others.
  • The supervisory authority regarding personal data protection is the Commission for Personal Data Protection.
  • Any person who loads our page in their web browser or visits its various sections and pages (regardless of whether by directly entering the e-mail address in the browser or by referring from another Internet site or resource) is a visitor.

A visitor is any person who has loaded
When visiting the internet platform and sending a request for reservation, registration and/or email to us, you, on your own initiative and desire, voluntarily provide “Klasman Enterprises” OOD with information concerning you, and you agree to the information being processed for feedback to you and for the purposes of the selected travel service.
The services provided on the internet platform of Klasman Enterprises Ltd. are intended for adults only.

  • Categories of data that can be processed: Online identifiers stored in local cookies on the visitor’s device/browser; Location data provided by the visitor, or their device, with the permission of the visitor; Country/city data based on the IP address of the user’s device, an invariable part of the information received from each website; Information about actions performed by the entity on the Platform; Preferences of the subject regarding specific aspects and settings of the platform’s functionalities; Information about the type of browser/device used.
  • Purposes of processing: Provision of basic and auxiliary functions necessary for the correct and full functioning of the Platform; Counting visits to the Platform; Provision of necessary conditions for implementation of services on marketing platforms.
  • Storage period: Until the expiration of the validity of each “cookie” (up to 1 year from the moment of its recording), carrier of the relevant information, or until it is deleted by the subject in whose device/browser it is stored.
  • Legal basis for processing: Consent to the Cookie Policy.

What is the purpose of this document?

This notice describes how we collect and use your personal information before, during and after the completion of the basic and/or additional travel services we provide.
All activities described here are in compliance with the General Data Protection Regulation (Regulation 2016/679) (GDPR). The notice may provide useful information to all future, current and former users of travel services.
As a personal data controller, Klasman Enterprises Ltd. is responsible for the decisions it makes regarding the storage and use of your personal information. Under the Data Protection Act, we have an obligation to provide you with the information contained in this notice.
Therefore, it is important that you read this notice carefully to understand how and why we use your personal information.

1. Data Protection Principles

We will comply with data protection legislation as follows:

  • To be processed lawfully, in good faith and transparently;
  • To be collected only for valid purposes that we have clearly explained and not to be used in any other way that is not compatible with those purposes;
  • Be appropriate, related to, and not in excess of what is necessary for the purposes we have specified;
  • To be accurate and up-to-date;
  • To be stored for a period not longer than necessary for the purposes we have indicated;
  • To be properly protected.

2. What information do we have about you?
“Personal data” or “personal information” means any information about an individual by which that individual is or can be identified.
There are special categories of more sensitive personal data that also require a higher level of protection.
We will collect, store and use the following categories of personal data about you:

  • Cyrillic/Latin names according to the national document;
  • Address, telephone number and/or e-mail address for contacting you;
  • Date of birth;
  • Gender;
  • Citizenship;
  • Type of identity document, number of identity card/ valid national identity document, country issuing the national document;
  • Data about the tourist service provided to you – date and time of arrival/registration, room/apartment, date and time of departure and other legally required data;
  • Personal data of persons under the age of 18, whose legal representative you are;
  • Data collected during payment made to us – credit or debit card number, bank account and other information collected during processing in connection with the payment by bank transfer, direct debit or through the Klasman Enterprises OOD Pos-Terminal ;
  • data from your account to access our online booking platform – username, booking and payment history;
  • Digital data – video recordings. This is the data collected through the video surveillance systems used by “Klasman Enterprises” OOD in all publicly accessible places of the “Longoza” hotel complex, Sunny Beach resort (lobby, reception, restaurant, entrances, etc.), with the aim security, monitoring, control and protection of public order;
  • IP address when visiting our website/online booking platform;
  • Data in connection with a complaint made regarding a tourist service provided by us and used by you;
  • information about the type and content of your booking and any other information related to it, including e-mails, letters, requests, requests, complaints, complaints and other feedback we receive from you;
  • It is also possible for us to process, if necessary, the following special categories, more sensitive data about you:
  • Information about your state of health;
  • Information about illegal actions on your part.

3. How do we collect your personal data?
We collect your personal data when we have a legal obligation to do so or when you have voluntarily provided it to us.
The basis for processing and storing personal data is the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to the conclusion of such a contract.

4. How will we use your personal data?
We will only use your personal data where permitted by law. We will most often use your personal data on the following grounds:

  • to perform our contract with you;
  • to comply with a legal obligation;
  • when it is necessary for our legitimate interests (or those of third parties), for example when it is necessary to seek legal protection against wrongdoing by you.

We may also use your personal data in the situations listed below, but we expect these to occur rarely:

  • to protect your interests (or the interests of someone else), for example when providing emergency medical care;
  • when processing is in the public interest.

5. Situations in which we will use your personal data
We will use the categories of personal data listed above primarily to fulfill our contractual obligations to you and to comply with our legal obligations. In some cases, we may use your personal data for our legitimate interests or those of third parties, but only if your interests or fundamental rights do not override those interests. The situations in which we will process your personal data include:

  • Provision of information to the Ministry of the Interior, the competent municipality for the location of the hotel, the Commission for Consumer Protection and the Commission for the Protection of Personal Data, in connection with the fulfillment of our obligations as a hotelier, arising from the current legal acts in this area;
  • Processing certain personal data to comply with the company’s legal obligations under the Tourism Act, the Civil Registration Act, the Accounting Act and other applicable regulations, as well as to protect the legitimate interests of the controller or a third party;
  • Processing your data in invoices issued in your name for other purposes compatible with the original purpose of their collection;
  • Carrying out tax and insurance control by the relevant competent state authorities;
  • Provision of information to the court and third parties within the framework of proceedings before a court, in order to protect their legitimate interests, including collection of receivables from customers by court order;
  • When you want us to make a reservation and confirm it, we will take the necessary actions for the administration of these services by identifying the client when: making, changing and canceling a reservation, as well as when providing tourist services for accommodation and meals, as well as all other services, provided on site at the hotel.
  • Customer identification is carried out through all commercial and communication channels – at the Hotel reception by providing an identity document, by phone, on our online platform through an electronic contact form, by e-mail, etc.;
  • When we update your personal data or the information about services in the Hotel according to your request for correction/change of data/services;
  • When servicing and responding to customer complaints/inquiries/complaints. Corrections of amounts due for already made reservations for accommodation and meals, if there is a reason for this;
  • When using the hotel’s website and other booking channels, you should take into account that information is collected automatically, some of which may be personal data. This includes data such as personal data, language settings, IP address, location, device settings, device operating system, log information, usage time, requested URL, status report, user agent (browser version information), operating system, result (browser or booker), browsing history, user’s Booking ID and type of browsing data.
  • When we use your contact details to invite you by email to write your guest review after your stay. This can help other travelers choose the accommodation that is best for them. If you submit a review as a guest, it may be published in space on our website.
  • When we send you personalized, interactive messages in connection with researching, developing, managing, maintaining and improving the hotel service or providing information about new products and services that you may be interested in and/or special offers from us
  • There may be other occasions when we will contact you by email, post, telephone or text message depending on the contact details you share with us, we may need to respond to or process requests made by you.

For some of the activities listed above, we may have more than one legal basis for processing your personal data.

6. If you do not provide us with the personal data that we require
Failure to provide the personal information you request may prevent us from performing our contract with you or complying with a legal requirement.
Your refusal to provide the necessary information for the fulfillment of the rights and obligations under the contract may be the reason for its not being concluded or for its termination.

7. Change of objectives
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If we need to use your personal data for another purpose, we will notify you and explain the legal basis for this use.

8. How will we use sensitive personal data?
Special categories of sensitive personal data require a higher level of protection and an additional basis for their collection, storage and use. We may process special categories of personal data in the following situations:

  • in limited cases, with your express written consent;
  • to comply with our obligations under the law;
  • when the processing is for the protection of public interest.

In rarer cases, we may process sensitive data where this is necessary for the defense of a legal dispute or to protect your interests or those of someone else and you are unable to give valid consent, or where you have disclosed this sensitive information in the public space.

9. Do we need your express consent?
We are under no legal obligation to obtain your consent when we process sensitive personal data in order to fulfill our obligations under the law.
However, we believe that we will obtain your express, voluntary and informed consent based on the information you provide here.

10. Information relating to convictions and offenses
We may use information related to violations only where permitted by law. This will normally be where this processing is necessary for us to comply with our legal obligations.

11. Data Sharing
We may share your personal data with third parties, including service providers (and other entities – subsidiaries).
We require all third parties to respect data security and comply with data protection legislation.
(We may send personal data to countries outside the European Economic Area (EEA), but even then you can expect a similar level of protection for your personal data.)
We will share your personal data with third parties when required by law, when necessary for the administration of the employment relationship or when we have another legitimate interest in doing so.
These third parties may include: hosting service providers, legal and TPR services and others.

12. How do we ensure the security of your information when we provide it to third parties?
All service providers are required to take appropriate security measures to protect your personal information. They may not use your personal data for their own purposes, but only for the purposes we have determined and in accordance with our instructions.

13. Data Security
We have implemented appropriate measures to prevent the accidental loss, use or unauthorized access, alteration or disclosure of your personal data. In addition, we limit access to your personal data to those employees and third parties who have a need to receive this information. They will only process personal data based on our instructions and in accordance with their obligation of confidentiality.

14. How long will we use your personal data?
We will keep your personal data only for the period for which we need it to fulfill the purposes for which we collected it, including to comply with legal requirements.
To determine the appropriate retention period, we take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process it or whether we could achieve those purposes with other funds, as well as applicable legal requirements.
In some situations, we may anonymize your personal data so that it can no longer be associated with you. As a result, we may continue to use the anonymized data without notifying you. After the termination of your contractual relationship with us, we will store your information in accordance with our policies and legal requirements and destroy it in a secure manner after the retention period described in our policies and regulated by law has expired.

15. Right of access, correction, erasure and restriction Your obligation to notify us of a change
It is important that we keep your personal information accurate and up-to-date. Please notify us of any changes to your personal data.

Your rights in relation to your personal data:

  • Access to information: this right gives you the opportunity to obtain a copy of the personal data we hold about you and to check whether we have a legal basis for processing it.
  • Rectification: this right enables you to ask us to correct any incomplete or inaccurate information about you.
  • Deletion: this right enables you to ask us to delete or remove your personal data when we have no valid reason to continue processing it. You also have the right to request that your data be deleted or removed when you have exercised your right to object to its processing.
  • Object to processing: in cases where we rely on our legitimate interests as a basis for processing, you can object to this processing.
  • Restriction of processing: this right gives you the possibility to ask us to temporarily stop processing your personal data if, for example, you want to establish the accuracy of the data or the reasons for its processing.
  • Data portability: this right is limited to cases where data has been provided to us by you for the purposes of a contract and enables you to require us to provide your data stored in electronic form to a third party.

If you wish to exercise any of your rights described above, please contact: an official from “Klasman Enterprises” LTD at tel: +359 56 82 55 11
Upon such request by you, we may need you to provide us with information confirming your identity. This requirement is part of our data protection measures and aims to ensure that personal information is not provided to a person who does not have the right to receive it.
You have the right to file a complaint at any time with the Commission for Personal Data Protection, the Bulgarian data protection regulatory authority.

16. Right to withdraw consent
In the event that you have provided your express consent to the processing of your personal data for a specific purpose, you have the right to withdraw this consent. To withdraw your consent, please contact an official from “Klasman Enterprises” LTD at tel: +359 56 82 55 11. Upon receipt of your request, we will cease processing the data for the purpose(s) for which you originally consented, unless we have another legal basis to continue processing, of which we will notify you in a timely manner.

17. Data Protection Officer
We have appointed a data protection officer to oversee compliance with data protection legislation within our organisation. You can contact him at +359 56 82 55 11
Changes to this notice

We reserve the right to change and update this notice at any time. We will provide you with a new notice each time we make changes.
By agreeing to this Privacy Policy, you expressly consent to us processing your personal data.