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General Terms and Conditions

PRINCIPLES FOR PERSONAL DATA PROCESSING

The policy of SUGAR JOB EOOD aims to ensure compliance with the provisions of the Regulation.

SUGAR JOB EOOD collects and processes personal data lawfully, fairly, and in accordance with the principles and rights of individuals in relation to the processing of their personal data.

SUGAR JOB EOOD processes personal data of individuals only in the following cases:

  • processing is necessary for compliance with a legal obligation of SUGAR JOB EOOD;
  • processing is necessary for the performance of a contract (including an order) with SUGAR JOB EOOD to which the individual is a party, or in order to take steps at the request of the individual prior to entering into a contract, when identification is required;
  • the individual has given explicit consent for a clearly defined, transparent purpose by SUGAR JOB EOOD, for which the processing of their personal data is required;
  • processing is necessary in order to protect the vital interests of the individual whose personal data are being processed or of another natural person;
  • processing is necessary for the purposes of the legitimate interests pursued by SUGAR JOB EOOD or by a third party, in accordance with the provisions of the Regulation;
  • other cases provided for in the Regulation.

SUGAR JOB EOOD does not collect or process personal data of individuals beyond what is required by law or necessary for its business operations.

In all cases where collected and processed personal data must be used for purposes other than the original ones, SUGAR JOB EOOD shall inform the respective individuals, request their consent, and proceed with the processing of their personal data for such additional purposes only after obtaining their explicit consent.

SUGAR JOB EOOD collects and processes only the minimum necessary personal data of individuals, which:

  • are required by law;
  • are necessary for the performance of a contract;
  • are necessary for the fulfilment of the purposes for which they are collected.**

SUGAR JOB EOOD ensures that the processing of personal data of individuals is carried out with maximum accuracy and, where possible, kept up to date.

SUGAR JOB EOOD ensures that access to and processing of personal data is carried out by the minimum necessary number of persons (operators) who have the required competence for such processing and the necessary commitment to their protection.

RETENTION PERIODS

SUGAR JOB EOOD stores personal data for the following periods:

  • Data from the tourist accommodation register under Article 116 of the Tourism Act, which includes identification data of accommodated persons and data related to hotel accommodation – in accordance with the terms and periods provided by the Tourism Act and applicable secondary legislation.
  • Information related to requested and used services for hotel accommodation, events, and restaurant services, including cancelled reservations (to the extent they are related to refunds and/or retention of due amounts) – from the moment of the reservation/request up to 5 (five) years after the provision of the service/completion of the contract/cancellation of the reservation. In cases where services are requested and used under a long-term contract, the period starts from the final execution and/or termination of the contract.
  • Financial and accounting documents; invoices; authorization forms; and other information related to tax and social security control – up to 10 (ten) years, starting from the beginning of the year following the year in which the payment obligation for the respective year is due.
  • Unstructured communication, correspondence, complaints, signals, and similar – 5 years.
  • Video surveillance data – up to 1 week.
  • Data processed on the basis of the explicit consent of the data subject – from the moment consent is given until it is withdrawn by the data subject.
  • Data until deletion is requested by the individual, where there is a valid legal basis for such a request.

The personal data specified in this Policy may be processed for a longer period than those indicated above if this is necessary to achieve the purposes set out herein, or for the protection of the rights and/or legitimate interests (including through legal proceedings) of SUGAR JOB EOOD, or if applicable legislation requires data processing for a longer period.

In all cases, SUGAR JOB EOOD ensures that a review of the collected and processed personal data is carried out at least once a year, and data falling under any of the above conditions are deleted without undue delay.

RULES FOR PERSONAL DATA PROCESSING

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

SUGAR JOB EOOD ensures the required levels of physical, organizational, and technological protection, taking into account:

  • the nature, scope, context, and purpose of the personal data being processed;
  • the likelihood, level of impact, and severity of risk to the rights and freedoms of individuals in the event of a personal data security breach;
  • its financial and organizational capabilities.

SUGAR JOB EOOD also ensures 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.

SUGAR JOB EOOD ensures the necessary and appropriate technical, organizational, and technological measures for controlled and traceable access to personal data of individuals.

Personal data is processed with the required accountability for compliance with the Regulation.

SUGAR JOB EOOD ensures the necessary accountability and records to be able to demonstrate compliance with the provisions of the Regulation.

DATA SUBJECTS

In connection with the services provided, SUGAR JOB EOOD processes information relating to the following categories of data subjects:

  • natural persons visiting the hotel’s website;
  • natural persons making reservations on their own behalf or on behalf of another natural or legal person through the Website;
  • natural persons using the services provided by SUGAR JOB EOOD, including but not limited to hotel accommodation services, restaurant services and related hospitality services, provision of premises for events, as well as natural persons representing or otherwise acting on behalf of legal entities that use these services.

The services of SUGAR JOB EOOD may only be requested by legally capable individuals who are at least 18 years of age

RIGHTS OF INDIVIDUALS WHOSE DATA ARE PROCESSED

SUGAR JOB EOOD ensures compliance with the rights of individuals whose personal data are collected and processed, which include:

  • the right to be informed about the processing of personal data;
  • the right of access to personal data – to know what data is held;
  • the right to rectification of inaccurate personal data;
  • the right to erasure of personal data – the “right to be forgotten”;
  • the right to restriction of processing of personal data;
  • the right to be informed about actions taken following a request for rectification, erasure, or restriction of processing of personal data;
  • 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.

PROCESSED PERSONAL DATA

Personal Data Processed in the Capacity of Controller:

  • employees;
  • individual customers;
  • individual suppliers.

PURPOSES OF PERSONAL DATA PROCESSING

SUGAR JOB EOOD, as a Data Controller, performs the following operations and processes only the personal data necessary for the following purposes:

  • conclusion, performance, and termination of employment contracts, as well as calculation of salaries and compensation for employees;
  • receiving, administering, and processing reservations and cancellations;
  • administration, execution, and delivery of purchases made through the Website;
  • administration and receipt of payments for provided services, including remote payments;
  • provision of services to clients;
  • ensuring an individualized approach in service delivery, in accordance with users’ stated preferences;
  • conclusion and performance of contracts with individual suppliers;
  • direct marketing for sales purposes.

RECIPIENTS AND CATEGORIES OF RECIPIENTS

In connection with the fulfilment of the purposes set out above, SUGAR JOB EOOD provides personal data of individuals to the following recipients:

  • the National Revenue Agency (NRA) in relation to payroll calculation for staff;
  • the National Social Security Institute (NSSI) in relation to the calculation of employee benefits;
  • occupational health service providers in relation to the obligation to maintain up-to-date employee health status and to carry out periodic medical examinations;
  • the General Labour Inspectorate, NSSI, and the Ministry of Interior in relation to workplace accidents;
  • the Ministry of Interior in relation to the submission of information about hotel guests;
  • other state and municipal authorities and/or institutions in relation to legal obligations or lawful requests for information containing personal data;
  • subcontractors engaged for the fulfilment of contractual obligations.

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 may contact us at:

  • E-mail: [email protected]
  • Phone: +359 877 774377
  • Address: 66 Via Pontica St., Sozopol, Burgas Region, Bulgaria

COMPETENT SUPERVISORY AUTHORITY

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

If you believe that your personal data protection rights have been violated, you may submit a complaint to:

  • Address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria
  • E-mail: [email protected]
  • Phone: +359 2 915 3518**