PRIVACY NOTICE FOR CLIENTS

The protection of personal data is of utmost importance for Terra Tour Service EOOD (‘Terra Tour Service’, ‘we’, ‘us’).

Terra Tour Service respects your privacy and confidentiality and is responsible for complying with the provisions of the General Data Protection Regulation and the existing Bulgarian legislation on the protection of personal data.

By this privacy notice, we inform you as to how Terra Tour Service collects and uses your personal data in your capacity as a customer.

Data Controller
The controller of your personal data is Terra Tour Service, a company incorporated in the Republic of Bulgaria and entered in the Trade Register with the Registry Agency under Company No (EIK) 040902318, 1111 Sofia, Slatina District, 67А Postoyanstvo Str.

Should you have any questions regarding this privacy notice or the personal data processed by Terra Tour Service ЕООD, you may contact us at: dpo@tts.bg or write to: 1111 Sofia, Slatina District, 67A Postoyanstvo Str., DPO. We will reply within 30 days or sooner if possible.

Purposes and grounds for processing personal data
Your personal data are processed in connection with and for the purposes of the provision of main and ancillary services by Terra Tour Service during or in connection with our hotel business: services relating to the reservation and provision of hotel accommodation, restaurant services, spa and wellness services, entertainment services, event management services, such as conferences, parties, seminars and other services provided in the hotels or other facilities we manage.

For the purposes of guarding, controlling access and ensuring your security and the security of the other customers in the use of services provided by Terra Tour Service, we collect your personal data by video surveillance of public areas and the common premises in the buildings we operate (entrances, reception desk, lounge, restaurant, bar, passageways, staircases, etc.).
We also use your personal data to provide you with up-to-date information and price offers on the services we provide (advertising and marketing), and also to ensure a tailor-made approach in the delivery of our services (customer service).

Terra Tour Service collects and stores your personal data on the grounds of fulfilment of legal and contractual obligations, taking steps prior to entering into a contract, and on the basis of legitimate (legal) interests of Terra Tour Service or of our customers.

Terra Tour Service processes your personal data only for the purposes for which they were collected, unless the processing for other purposes is compatible with the original purpose.

In case Terra Tour Service will process your personal data for other purposes that are incompatible with the original purpose for which they were collected, Terra Tour Service will notify you accordingly and will inform you of the legal ground that allows the processing for such other purposes.

Terra Tour Service does not need your consent to process your personal data for the purpose of the main (and ancillary) tourist services provided by Terra Tour Service during and in connection with the hotel activity. In limited cases, Terra Tour Service may request you to provide your explicit written consent to allow the processing of your personal data for other purposes, such as to be shared with Terra Tour Service’s partners, for you to receive information or price offers on the use or supply of certain services and goods.

In all these cases, you will be provided with full and clear information in advance so that you can assess whether you wish or not to give your consent. Please note that granting your consent to the processing of personal data is not a condition for the use of the main and ancillary tourist services we provide.

1. Reservations and requests
Terra Tour Service, on the basis of contractual obligations and taking steps prior to entering into a contract, processes the following personal data for making reservations: names, age, nationality, telephone number, e-mail address, date and time of arrival, date and time of departure, number of your companions and their age, room type (for smokers or non-smokers, single, double, etc.) and your special preferences, if any, such as a room overlooking a natural attraction, with special equipment, etc.

On the grounds of fulfilment of legal and contractual obligations in relation to your reservations, Terra Tour Service processes your personal data relating to the payment and issuance of an invoice (bank, IBAN, account holder, payment currency, number, validity and holder of the credit/debit card, CVV/CVC code, personal identification number or any other identification number, and other information collected in relation to the payment).

For enquiries about the services we provide, which you make via any of our websites, emails or by phone, Terra Tour Service processes: your names, telephone number and email address, on the grounds of taking steps prior to entering into a contract for the provision of up-to-date information and a price offer on the services offered.

2. Hotel accommodation
In the accommodation process, Terra Tour Service has a legal obligation to register you and to collect your names, personal identification number or foreigner‘s identification number, date of birth, sex, nationality, ID document, country of issuance of the identity document, validity date of the identity document, date of arrival, date of departure, number of nights spent, use of a tourist package, the floor and number of the room in which you are accommodated.

In order to comply with its legal and contractual obligations, Terra Tour Service processes your personal data relating to the payment and issuance of an invoice (bank, IBAN, account holder, currency of payment, number, validity and holder of a credit/debit card, CVV/CVC code, personal identification number or any other identification number, and other information collected in relation to the payment) that are required for invoicing, paying and reporting your hotel accommodation. When you purchase hotel accommodation using a voucher, we also process the voucher number.

3. Restaurant services
When providing restaurant services on the ground of fulfilment of our legal and contractual obligations, we process: your names, personal identification number or foreigner‘s identification number, your personal data related to the payment and issuance of an invoice (bank, IBAN, account holder, payment currency, number, validity and holder of a credit/debit card, CVV/CVC code, personal identification number or any other identification number, and other information collected in relation to the payment).
When you explicitly state your specific requirements regarding food or drink, we process your preferences in the use of restaurant services on the ground of fulfilment of our contractual obligations towards you.
4. Spa and wellness services, entertainment services, event management and other services provided in the hotels and other facilities we manage
When providing spa and wellness services, entertainment services, event management and other services provided in the hotels and other facilities we manage, on the ground of fulfilment of our legal and contractual obligations, we process: your names, personal identification number or foreigner‘s identification number, your personal data related to the payment and issuance of an invoice (bank, IBAN, account holder, payment currency, number, validity and holder of a credit/debit card, CVV/CVC code, personal identification number or any other identification number, and other information collected in relation to the payment).

Due to their specificity, golf tournament arrangement activities and the provision of access to the golf course require collecting the following personal data: names, e-mail address, telephone number and handicap. The ground for the processing of your personal data when granting access to the golf course is the fulfilment of our contractual obligations towards you. When informing you of upcoming golf tournaments and events, we process your personal data on the grounds of our legitimate interest to send you information on our services. The objective of collecting and processing personal data is to inform you about upcoming events related to our golf-related activities.

When you explicitly state your specific requirements for the provision of these services, we process your preferences on the basis of fulfilment of our contractual obligations towards you.

5. Customer and membership cards
Being our client, you have the right to ask for a customer card to be issued to you. Your customer card allows us to identify you as a customer who has already used our services and to offer you preferential prices when you use some of our services. For members of Pravets Golf Club, we also issue membership cards for access to the golf course. When issuing a customer and a membership card, we collect/process the following data: your names, date of birth, address, telephone number and e-mail address. These data are collected/processed on the grounds of legitimate interests of Terra Tour Service to provide up-to-date information and price offers on the services we provide (advertising and marketing) and to provide a tailor-made approach to the provision of our services (preferences).

6. Marketing and advertising
On the basis of the legitimate interest of Terra Tour Service to provide you with up-to-date information and price offers on the services we provide, we use your names and e-mail address you provide to send you information on our specific offers, promotions and discounts. In the event that you do not wish to receive such communications, you can always declare your refusal and any further submission of such information will be ceased.

7. Website
When you visit our website www.tts.bg to review it and/or make a query about any of our services, we collect data on your use of the website via so-called ‘cookies’. Cookies are small text files, the purpose of which is to remember the device (a computer, a mobile phone) through which you visit the website for the first time. Cookies are of different types. Some of them are needed to operate our site. Others are needed to improve the functioning of our website by collecting anonymised information on which parts of the website are more frequently visited. The abovementioned cookies do not collect personal data.
Cookies which collect personal data are of two types: cookies intended to improve the use of the website by remembering your preferences, such as the language used, font size, location, etc., and the so-called ‘advertising cookies’. Advertising cookies collect data on which sites you visit, and thus you guide us which products can be offered to you. The ground for using cookies that collect personal data is our legitimate interest to know your preferences so that we can offer services that will best meet your wishes and needs.
All the categories of cookies can be stopped through the cookie settings menu, except those that are indispensable for the functioning of the relevant website.

8. Real property and real property management
When you purchase and/or rent real property, a house and/or an apartment, Terra Tour Service has a legal obligation to collect your names, personal identification number or foreigner‘s identification number, mailing address, e-mail address, date of birth, identity document number, country of issue of the identity document, validity date of the identity document, the date of the conclusion of a contract for the purchase or lease of property, the date of termination of a lease contract, and the number of a contract for the purchase of property.

When fulfilling our legal and contractual obligations, Terra Tour Service processes your personal data relating to the payment and issuance of an invoice (bank, IBAN, account holder, payment currency, number, validity and holder of a credit/debit card, CVV/CVC code, personal identification number or any other identification number, and other information collected in relation to the payment) that are necessary for invoicing, paying and reporting the services and properties you use, drawing up preliminary and final contracts for the purchase and management of property.

9. Video surveillance
Terra Tour Service processes personal information of individuals on the grounds of our legitimate interest when carrying out video surveillance and control of access, in order to secure property and to ensure the physical security of our guests and visitors. Video surveillance and video recording are carried out in public areas and premises in the buildings of Terra Tour Service’s facilities, as well as in those for which a specific access regime is provided. No video surveillance is carried out in guest rooms and sanitary premises. Guests and visitors are informed of the use of technical means for surveillance and control by easily visible information boards.

Collection of personal data
Terra Tour Service collects personal data directly from its customers at the time of their registration in the accommodation facilities or when they make reservation by e-mail or phone, and indirectly in the case of reservations made through a tour operator or a travel agency.

Special cases in which personal data of data subjects are collected: when a person other than the data subject makes a request for services for the benefit of the data subject (for example, when your employer requests services that you will use as an employee).

Recipients of personal data
Terra Tour Service has a legal obligation to provide the personal data of its clients to public authorities responsible for the control of hotel and restaurant activities, such as the Ministry of Tourism, the National Revenue Agency (NRA), the Ministry of Interior, the Commission for Consumer Protection, the judicial authorities, etc.

Terra Tour Service enters into contracts with other subcontractors and partners to which Terra Tour Service transmits personal data necessary for the provision of certain main and ancillary tourist services, such as transport companies, airlines, recreational organisations, etc.

Your personal data may be provided to third party partners which, on the basis of an existing contract and a confidentiality commitment, assist Terra Tour Service in the fulfilment of legal obligations by performing services such as accounting and auditing, maintenance of IT systems, etc.

The recipients of your personal data are also advertising networks through the so-called ‘advertising cookies’ that you allowed when you visited our website.

Storage duration
Terra Tour Service will process and store your personal data for as long as it is necessary to achieve the purposes for which your personal data has been collected and to meet the legal requirements for storing these data for a specified period.

Personal information collected by us when reservations are made and accommodation and restaurant services are performed is kept and stored for 5 (five) years from the date on which you leave the hotel. In all cases, personal data are kept until the final settlement of all financial relations between the parties, depending on the regulatory requirements. Personal data contained in the accounting and financial documents are kept for the purposes of tax and social insurance control for the statutory time limits of at least 10 (ten) years as of 1 January of the reporting period following the reporting period to which they refer, unless the legislation provides for a long period.

It is possible to store personal data for longer periods in order to protect our legitimate interests, and also until the expiry of the relevant limitation period for the purpose of defence in case of legal claims by clients. In the event of a lawsuit, personal data will be stored until its resolution by a final judgment or an arbitral award.

Video records made by technical means of control are kept for 30 days from the recording.

Cookies data are stored until you change your cookies preferences and ban the use of the categories of cookies that collect personal data.

We will destroy your personal data promptly and as practicable after the end of their retention period and in a way preventing their reproduction or restoration.

Security

Personal data you provide will be treated by Terra Tour Service as strictly confidential.

In order to ensure the security of personal data, Terra Tour Service applies technical and organisational measures to protect them against unauthorised access, loss, theft and abuse, disclosure, alteration or destruction. Access to your data in Terra Tour Service is restricted to persons whose employment functions are related to access and processing of data.

Terra Tour Service requires its suppliers, subcontractors and partners that have access to your data to take appropriate technical and organisational measures ensuring the protection and confidentiality of your data.

In the contracts with our employees and third parties engaged by us to process your personal data, we include contractual clauses on the confidentiality of personal information to which they have access.

Your rights
You have the following rights in relation to your personal data processed by Terra Tour Service:
1. Right of access
You have the right to request, at any time, more detailed information on the processing of your personal data by Terra Tour Service. You may request a copy of your personal data stored by Terra Tour Service.

2. Right to rectification
In case your personal data processed by Terra Tour Service are inaccurate, you have the right to request for them to be rectified.

3. Right to data portability
You have the right to request from us your personal data or transfer them to another controller in a structured, commonly used and machine-readable format. This right is applicable where your personal data have been collected and used for the fulfilment of Terra Tour Service’s contractual obligations, or are processed on the basis of your explicit consent.

4. Right to erasure
You have the right to request us to erase your personal data in cases where they are processed for the performance of contractual obligations, a legitimate interest or based on your explicit consent, and on any of the following grounds: (1) your personal data are no longer needed for the purposes for which they were collected; (2) where the processing of your personal data is unlawful; (3) when you object to the processing of your personal data and there is no legal basis for the processing of your personal data; (4) when you withdraw your consent on the basis of which your personal data are processed; (5) when your personal data must be erased in order to comply with a legal obligation.

5. Right of withdrawal
In case the only basis for processing your personal data is your consent, you have the right to withdraw it for the future.

6. Right to restriction
You have the right to restrict the processing of your personal data: 1) when you have made a request for your personal data to be rectified, for the time needed to adjust them; (2) where the processing is unlawful and you oppose the erasure of your personal data, but request the restriction of their use instead; 3) when your personal data is no longer needed by Terra Tour Service but you would like they to be kept for legal claims purposes; (4) when you have objected to the processing of your personal data, pending the verification whether a legal basis for the processing exists.

7. Right of objection
You have the right to object to the processing of your personal data where the processing is carried out on the grounds of the legitimate interest of Terra Tour Service or a third party, for the performance of a task carried out in the public interest, or in the exercise of official authority, including profiling on the same grounds. In such cases, if we cannot prove that compelling legitimate grounds exist for the processing that take precedence over your interests, rights and freedoms, or that the processing is necessary for the establishment, exercise or defence of legal claims, we will discontinue the processing of these personal data.

You have the right to object at any time to the processing of your personal data for direct marketing purposes, which includes profiling as long as it relates to direct marketing. Terra Tour Service informs you in due time of the existence of the abovementioned right to object by means of a notification, distinct from any other information.

8. Right to lodge a complaint

Terra Tour Service EOOD makes every effort to comply with all existing and binding rules and security measures for the handling of personal data, and therefore we believe that there will be no situations in which you could be dissatisfied with our behaviour towards you.
Should any problems arise, you have the right to contact the supervisory authority.
The supervisory authority is the Commission for Personal Data Protection (CPDP) with address: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd. (www.cpdp.bg).
Terra Tour Service reserves its right to change this privacy notice, in which case you will be given the opportunity to take cognisance of the updated privacy notice.