Luxury Villa Borina, located in the villa zone Yarema, Sofia Region, is managed by the company “Borina” Limited, with UIC:206127775, with registered office and address of management Sofia, PC 1618, Reg. Vitosha, “Ivan Susanin” str. 26A, 4th floor, appartement 13 ("the Company", "We", "Us") a company which is focused on the provision of tourist accommodation services and management of tourist sites. The Company is also responsible for the maintenance of the website https://luxury-villa-borina.com/ and all its contents, having exclusive rights over the published pictures, graphics and contents.
In carrying out our activities, the protection of your data and your privacy are a top priority for us, and therefore we strive to process them in minimization of the data to the necessary minimum and in limiting deadlines for their storage, by applying appropriate technical and organizational measures for their security. We value the privacy of your life and health and the confidentiality of your data.
"Personal Data Administrator" is a person who alone or jointly with another person determines the purposes for which personal data will be processed (collected, used and stored) on paper or in electronic form.
The Company will act as an administrator of your personal data when there is a reason for its processing, for example in connection with your reservation or stay with us; execution of your requests, applications and complaints to us or related to our activity; the execution of contracts with us to which you are party or you are a representative of a party or which are basis of your rights; the implementation of or protection against your claims against the Company; implementation of other legal/legitimate interests of the Company.
In certain cases the Company may process your personal data as a joint administrator with other administrators, which also process your data on a legal basis.
For the purposes of our accommodation activity, we process, for example, your full name, personal identification number or date of birth, place of birth, ID document’s data, arrival date, departure date, companions, phone number, email (in case of email communication with you).
Please consider that processing of your identification data is mainly because of the statutory obligations of the Company to identify the tourists and to keep records of them.
If the Company only communicates with you, the following data will be processed: your name, your email address, your phone number, your IP address, signature (perhaps, in case of written communication).
The general rule is that the types of data, which the Company processes, depend on our relations and the purposes the Company is aiming to achieve. Due to this reason, the types of processed data always vary but it’s under the Company’s control and in consideration of lawfulness and minimization of processing of personal data.
It is important to inform you that where the Company processes your personal data in connection with the performance of a contract to which you or the legal entity represented by you is a party or in connection to a request initiated by your side, there is a separate ground for processing of your personal data. Therefore, we have the right to process the above- mentioned personal data without your explicit written consent to processing.
The company does not collect and use personal data, revealing racial or ethnic origin, religious or philosophical beliefs or trade-union membership, and the processing of genetic data, data about the sex life or sexual orientation of the individual, therefore in the course of communication with the Company, you shall not disclose such data.
Cookies and technical data
Please consider that using the Website, you provide information to the Company which by itself does not have the character of ‘personal data’ or which can be considered as ‘personal data’ only in combination with other information or data gathered through the Website. The personal data which the Company will process in connection with the services provided through the Website are: name (surname and/or family name), email address, phone number, activity in social networks (Facebook, Twitter, You Tube etc.) – a minimal amount of data but necessary to provide the services you are looking for and to meet your expectations in the best possible way. When you use the Website, the Company will process data concerning your preferences and your interests. All of that data is processed to make the Website’s performance better and your interaction with it easier. The data may include information about:
Дружеството и трети страни (понякога доставчици на услуги на Дружеството) имат много начини да събират цялата посочена информация, включително:
Security vulnerabilities may allow a cookie's data to be read by a hacker, used to gain access to user data, or used to gain access (with the user's credentials) to the website to which the cookie belongs (see cross- site scripting and cross-site request forgery for examples).
The Company’s Website is using the following cookies:
The purposes for which we process your personal data are:
In order to achieve these objectives, the Company collects information about you in a variety of ways, whereas most commonly personal data is submitted by you or from public records.
The Company processes your personal data by the application of a number of technical and organizational security measures through various processing operations (including, but not limited by: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise, data become available, alignment or combination, restriction, deletion or destruction) carried out manually and automatically. The type and the way of performing the specific processing operations depend on the purposes of processing and of the business processes related to these purposes.
In the course of its processing activity, The Company may use processing programs, in respect of which, it monitors compliance with high security requirements and confidentiality of processed personal data.
It is important to note that, as indicated above, your consent to the processing of personal data is not the only legal one grounds on which the Company substantiates its data processing activity. Therefore, the Company will process information about you in accordance to the legal requirements, even in case you do not explicitly agree with this processing or if you have given your consent, and you have exercised your right to withdraw the consent thus given for processing.
The Company guarantees that your personal data will be processed only in accordance with the purposes set out above. In connection with these purposes, your data can be provided/disclosed/transmitted to third parties, acting as administrators of personal data, such as processors or as joint administrators, such as:
The Company ensures that your personal data is processed only in accordance with the objectives set out above. In conjunction with these goals, your data can be provided / disclosed / transmitted to third parties acting as administrators of personal data in their capacity as joint administrators or processors.
As mentioned above, the security of Your data is a priority for us and because of this the Company will not disclose / provide / transmit your data to third parties who do not possess the right to know information about you.
Your data is mainly processed on the territory of the Republic of Bulgaria and within the borders of the European Union(with exception when the services of Facebook, Instagram and Youtube, which are connected to the website and are provided by independent third parties, which have their own confidentiality policies).
Practices and methodologies for data protection and information security assurance implemented by us set out the parameters of the identified measures which aim to:
As a subject of personal data under Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (" The General Data Protection Regulation"), you have the following rights:
Можете да упражнявате описаните права с промяна на настройките на Вашия браузър или мобилно приложение, доколкото това е технически възможно, или като се свържете с нас на контактите, описани по-надолу, като попълните Формуляр за упражняване на права съгласно Общия регламент за защита на данните, който можете да намерите на Уебсайта https://luxury-villa-borina.com/ и го предоставите в нашия офис с адрес, посочен по-долу, на хартия.
Given the fact that the Company makes contacts (establishes relationships) with different categories of persons and on various occasions (including on the occasion of your actual and indirect participation in certain events), then the proper examination of the submitted by you application for exercise of rights is directly linked to the exact identification of the circumstances in which the Company had to process your personal data.
In the exercise of your rights as a subject of personal data for the Company arises the necessity to request and process certain personal data for the purpose of establishing and verifying your identity. As an administrator of personal data, the Company is not just obliged to provide means for you to exercise your rights, but also to guarantee that those rights will be exercised only by the subjects, which are actually entitled to the certain right, governed by the General Regulation on data protection.
Your application for the exercise of rights, will be processed in due course, in the most general case for not more than 30 (thirty) calendar days, except if your request is not specific and is not in connection with in depth examination of information. Still our team will do the necessary to inform you, by sending and email, in case of delays in the examination of your request. Given the fact that the Company highly values the necessity for protection of data, it has established and implements a procedure for the examination of request concerning the exercise of rights, in accordance with the General Regulation on data protection, in which the deadlines for examination of, and response to submitted requests for exercise of rights by subject of data, are stated.
The processing time of your data is also consistent with the processing purposes and with regulatory storage requirements of accounting and tax information. determining the deadline for the storage of your personal data is directly conditioned by the type of relationship, which we have established with you and due to which we have processed your personal data in the first place.
The company will not store your personal data longer than necessary, and will store them only for purposes for which have been collected.
Contact address: Bulgaria, Sofia, PC 1618, Vitosa Region, “Ivan Susanin” str., 26A, 5th floor, apartment 13.
Telephone Number: (+359) 888 737 656; (+359) 889 900 200
You can contact us by email at: email@example.com.
The Company has no obligation to appoint a Data Protection Officer, therefore there is no such.
On the occasion of the collection and processing of your personal data, you can refer to the Commission for Protection of Personal Data at the following address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., www.cpdp.bg
When is this Policy updated?
Преглеждаме настоящата Политика редовно. Последната актуализация на настоящата декларация е от 10.12.2020 год.