GDPR policy

Happy Tour Ltd.

Personal Data Protection Policy

PURSUANT TO: 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 (General Data Protection Regulation) and the Personal Data Protection Act.

1. The administrator of personal data is Happy Tour Ltd., entered in the Commercial Register kept by the Registry Agency with Unified Identification Code (UIC) 103258964, having its registered office and head office at the Havana Hotel in Golden Sands resort, city of Varna.

Happy Tour Ltd. considers the protection of your personal data a key priority.

In our capacity as controller and processor of your personal data provided to us, we recognise our responsibility for the decisions we make concerning their storage and use. We have an obligation under the data protection legislation to provide you with the information contained in this notification.

In its capacity as a personal data administrator, Happy Tour Ltd. has a well-established corporate policy on personal data protection, which requires that all personal data should:

  • Be processed lawfully, fairly, and transparently;
  • Be collected only for valid purposes that we have explicated clearly herein, and not be used in any other way that is incompatible with these purposes;
  • Be appropriate, related to, and not going beyond what is necessary for the purposes specified herein;
  • Be accurate and current;
  • Be kept for no longer than is necessary for the purposes specified herein;
  • Be adequately protected.

By using the services available through our website www.havana.bg you agree with this Policy and expressly confirm your acceptance thereof.

By completing the ‘Make an Enquiry’ form, the ‘Make a Reservation’ form or the ‘Make a Payment’ form, as well as when you apply for a job through our website’s ‘Careers’ section, you give Happy Tour Ltd., in its capacity as a personal data administrator, your explicit consent to have your personal data processed in accordance with the personal data protection regulations.

We will collect, store, and use the following categories of personal data:

1. In the ‘Make an Enquiry’ contact form:

  • Given name and surname, or given name, middle name, and surname;
  • Phone number and email address;

2. In the ‘Make a Reservation’ form:

  • Given name and surname, or given name, middle name, and surname;
  • Phone number and email address;

3. In the ‘Make a Payment’ form:

  • Given name and surname, or given name, middle name, and surname;
  • Phone number and email address;
  • Bank card data and bank account data.

4. When applying for a job through the ‘Careers’ navigation menu:

  • Given name and surname;
  • Phone number and email address;
  • Domicile;

All job applicants must submit a curriculum vitae as an attached file. Such CV must have the following mandatory content:

  • Personal identity number (EGN) or personal foreigner’s number (PFN);
  • Administrative address;
  • Phone number and email address;
  • Place of employment, work experience, level of education, professional qualifications, etc.

Purpose of data processing:

The personal data required from you are used for the normal functioning of the website owned by Happy Tour Ltd. The personal data are used also to provide the necessary conditions for the provision of certain service.

Storage period:

All personal data provided through the ‘Make an Enquiry’ form, the ‘Make a Reservation’ form, and the ‘Careers’ navigation menu are stored on a server located on the administrator’s premises for a period of up to one year.

All personal data provided through the ‘Make a Payment’ form are stored on the server of a hosting company under a contractual arrangement. Those are stored for three (3) days following the chargeable event or for three (3) days after checking out of the hotel unless otherwise required by another legal act or regulation.

Legal basis for the processing: Consent for our Cookie Policy and for our Website Usage Terms and Conditions; Informed Consent.

1. Use of personal data

We will use your personal data only as and to the extent permitted by law. We will most often use personal data on the following grounds:

  • For the performance of our contract with you;
  • For compliance with a legal obligation;
  • Where it is necessary for our legitimate interests (or those of third parties).

2. Change of purpose

We use your personal data only for the purposes we collected them for unless we make a reasoned judgment that we ought to use them for another reason as well and that reason is compatible with the original purpose. If we have to use your personal data for another purpose, we will notify you and will explain the legal grounds for such use.

3. Sharing of personal data

We may share your personal data with third parties.

We require all third parties to respect the security of your data and to treat it in accordance with data protection laws and regulations.

We will share personal data with third parties where required by law, where it is necessary for contract management and administration, for managing contractual obligations, or where we have another legal basis and/or legitimate interest in doing so.

4. How we will keep your information safe when provided to third parties

All service providers are obliged to take appropriate security measures to ensure personal data protection. They may not use any personal data for their own purposes except for the purposes we have specified under our instructions.

5. Data security

We have put in place appropriate measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees and third parties who have a business need to obtain such information. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6. How long we will keep and use your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected them for, including for the purposes of complying with the requirements of national accounting legislation.

7. Rights to access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed of any change to your personal data during your relationship with us.

Your rights in connection with personal data:

  • Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to verify whether we have lawful processing grounds.
  • Request correction of the personal data that we hold about you: This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data: This enables you to demand from us to delete or remove your personal data where there is no good reason for us continuing to process them. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing.
  • Object to processing of your personal data: Where we are relying on our legitimate interests as a processing ground, you may object to processing on this ground.
  • Request the restriction of processing of your personal data: This enables you to demand from us to suspend the processing of personal data about you, for example, if you want us to establish their accuracy or the reason for processing them.
  • Data portability: This right is limited to cases where you have provided your personal data to us for the purposes of a contract. It enables you to ask us to transmit your electronically stored personal data to a third party.

If you wish to exercise any of your rights as outlined above, please contact Happy Tour Ltd. – personal data administrator.

You have the right to lodge a complaint at any time to the Commission on Personal Data Protection, the national supervisory authority of the Republic of Bulgaria responsible for the protection of personal data.

8. Right to withdraw your consent

In the eventuality that you may have given your explicit consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Happy Tour Ltd. – personal data administrator. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legal basis to continue processing, in which case we will inform you promptly.

9. We reserve the right to amend and update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

If you do not want us to process your personal data in the ways described herein, you have the right not to provide them to us. The provision of personal data is entirely voluntary. Personal data are collected for the purposes of the full and proper functioning of our website and the provision of high-quality services to our customers. Your refusal to provide your personal data is equivalent to a refusal to use our services available through our website and a refusal to use the services of Happy Tour Ltd.

This Policy is an integral part of and complementary to our GDPR compliant cookie policy and the terms and conditions for using the www.havana.bg website.

All possible future changes to this Policy will be published on this website.

By accepting our Privacy Policy, you give us your explicit consent to the processing of your personal data.