Confidentiality Policy of Holiday Partner Ltd
Last update on 21.05.2018
Obligatory information on the rights of persons related to personal data protection
Name: Holiday Partner Ltd
UIC (ЕИК)/BULSTAT: 148096463 / BG148096463
Registered office: 27, “Debar” str., 9000 Varna, Bulgaria
Internet page: www.holidaypartner.eu
Information about the competent supervisory body for personal data protection
Name: Commission on Personal Data Protection
Legal residence and registered office: city of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Telephone: 02 915 3 518
Internet page: www.cpdp.bg
For the purposes of the present confidentiality policy, we shall introduce a definition of the following terms:
„PLATFORM/ PLATFORMS/ OUR PLATFORMS“ – The term refers to a virtual platform, owned by the Company, which encompasses the following websites:
1. Scope and consent:
Please kindly read carefully the present confidentiality policy. It clarifies issues related to what data and personal information we collect on our platforms – internet pages and the purposes they are used for. Prior to prividing personal data to us through our Webstie, you will be explicitly asked to accept our Confidentiality Policy. By accepting our Confidentiality Policy you agree that we collect and process your personal data for the purposes and in the manners described below.
By visiting and using the page and platforms of Holiday Partner Ltd, you declare that you have read, understood the contents and agree with the present Confidentiality Policy of Holiday Partner Ltd. If you do not agree with the present policy please do not use the platforms of Holiday Partner Ltd.
You should be aware that we can alter and update the present Confidentiality Policy from time to time. The upper part of this page mentions the date of the last update of the document, which is also its currently active version.
The practices described in this document are only applicable on our platforms, part of which this internet page is as well so we cannot guarantee their application on other internet pages this site redirects you to.
Providing personal data is voluntary. In the event you do not wish to provide us with your personal data, it will not be possible to use it for certain services offered on our platforms. As a result, you will not be able to use the services provided by us.
2. Grounds for processing of personal data:
In relation to the legitimacy of the processing of personal data, according to the General Data Protection Regulation (ЕС) 679/2016 from which the grounds on which Holiday Partner Ltd processes personal data ensue, these grounds are the following:
o processing is necessary for observing a legal obligation;
o processing is necessary for the performance of a contract;
o on the grounds of the consent granted by the data subject;
3. processing is necessary for the purposes of legitimate interests of Holiday Partner Ltd The information we collect:
Holiday Partner Ltd is obliged to ensure that the processing of data it receives and/or collects from you be processed in compliance with the active legislation and the principles adopted by virtue of the General Data Protection Regulation (ЕС) 679/2016 and for the purposes outlined in the present policy.
We will be processing the following categories of personal data:
o e-mail address;
o telephone number;
o date of birth;
o information from enquiries;
o information from reviews related to services rendered by Holiday Partner Ltd or third parties arising from an agreement between the User Holiday Partner Ltd;
o other personal information upon participation in games and/or contests;
User Holiday Partner Ltd;
o other personal information upon participation in games and/or contests
In addition to that, we automatically accept and record information fro the browser on:
o IP address;
o software and hardware characteristics;
o pages on the website you access;
o other system information;
If you have a profile in Holiday Partner Ltd, we will process your personal data provided in relation to the profile, for example:
o profile number;
o history of shopping;
The data we collect from you can be processed by staff working for Holiday Partner Ltd. Such staff may, inter alia, be engaged in the maintenance of that website, the performance of your order, the processing of details of your payment or providing support services.
4. Method of information collection:
o using our internet page – by cookies;
o when you register, creating a profile;
o when you forward a request;
o when you make a reservation (online or offline);
o when you register in order to receive electronic bulletins from us;
o when you take part in a questionnaire and/or study;
o when you take part in games, promotions and/or initiatives;
o when you present user content (reviews);
o by third parties – persons authorised to make a reservation for you;
o by third parties– through the profile of Holiday Partner Ltd in social media platforms such as Facebook, Twitter, Google+, LinkedIn, YouTube, or Instagram and/or by using those to register on our internet page.
5. In the present policy, the purposes and manners of processing your personal data are:
o in order to render our services;
o to connect with our users;
o in order to respond to your enquiries;
o in order to customise content;
o in order to improve our services;
o in order to improve the efficiency of our internet page;
o for marketing purposes;
o for research and analyses;
o other manners permitted or not prohibited by the legislation.
You explicitly agree with the collection, use, processing and providing of your information and data as envisaged by the present Confidentiality Policy, as well as with their provision for storage on servers rented or owned by Holiday Partner Ltd.
We shall store your data for a period no longer than the one provided for by the law.
6. Information about third parties – partners of the webstie
Holiday Partner Ltd will not provide personal data to third parties except in the case herein specified.
OUR PLATFORMS may contain links to or from websites of third parties, for example third parties, categorized as distributors, advertisers, service providers.
OUR PLATFORMS may contain links or redirect to websites or other platforms of social networks, for example Facebook, Google, Twitter, Instagram, etc. In case you follow the link to any of those websites, you should be aware that these websites have their own confidentiality policies and that Holiday Partner Ltd does not take any responsibility whatsoever for confidentiality policies applied by such third parties.
In view of the correct functioning of our website and in order to constantly improve the quality of the products offered we use the following programmes and web solutions, which could acquire access to your IP address and analyse your behaviour during your visit of our platforms, including this website, without this identifying you as a natural person:
Google Analytics - https://privacy.google.com/businesses/compliance/We use Google Analytics for collecting statistical information about the users of our internet page. An example is the internet page you are coming from to our page, the country you are in, your language, online behaviour, the browser you are using, etc.
You can refuse the use of your data by Google Analytics, by means of the add-on Google Analytics opt-out browser add-on, which you can download and install on yout web browser
Mailchimp – (https://mailchimp.com/legal/privacy/ ).). We share your information provided with your consent to third parties, which send promotional e-mails in our name and on our account. In order to stop receiving our promotional e-mails you can unsubscribe from the newsletter in each promotional message you receive from us.
As well as various Wordspress plugins
Google Webmaster tools - https://www.google.com/webmasters/;
Hotjar heatmap - https://www.hotjar.com/privacy/gdpr-compliance;
Twitter, Google plus, Instagram, Ремаркетинг, Google Adwords Conversion, Facebook Custom Audience.
In case you do not agree with these conditions you will not be able to make full use of our website and you should stop using it in the future.
7. The policy of using „cookies”
- What do Cookies constitute? – Cookies are small text files the website can use by recording them on your device. The purpose of cookies is to „remember“ your device and to recognise you upon your next entry into the website thus enabling the adapting of the website to the user’s preferences. All files collecting and memorizing such information are called cookies.
For more information please visit: http://www.allaboutcookies.org/cookies/what-information-in-cookie.html
- What are cookies used for?
o Cookies are used for various purposes. Holiday Partner Ltd relies on them in order to better select the site content according to your interests, to monitor what the visiting rate of the website is, for the site’s better functioning, etc.
o The greater part of cookies is used only with the purpose of finding out how Users reach the website or what their approximate location is. Nevertheless, there are also cookies storing personal information, for example remembering names and passwords.
The cookies used on this website are specified below:
o Necessary – needed for the use of the site. Without those cookies certain services and/or functionalities will not be possible to use.
o Operative – necessary for collecting information on the manners in which users use a specific website. The entire information collected by those cookies is summarised and therefore anonymous. It is used for the site improvement.
o Functional – necessary for the opportunity to monitor the choices the user makes on the site. In this manner, you are offers a more accurate, adequate and customised experience of the site. The information collected by those cookies can be transferred in anonymous form and your activity on other websites cannot be traced.
o Targeting – needed to display advertisements more appropriate for you and your interests and for limiting the cases when you see an advertisement, as well as for measurement of the efficiency of advertising campaigns.
In the event you are a registered user, the information collected by those cookies can be combined with your personal data.
If you wish to learn more about refusing behavioral advertising, please visit www.networkadvertising.org/managing/opt_out.asp.
Cookies can be deactivated by:
o Special instruments for refusal:
o The options of the browser
PC computer and Mac computer
You can also refuse by a statement to that effect forwarded to the e-mail contacts published above on this page.
8. In relation to General Data Protection Regulation (ЕС) 679/2016, your rights are expressed in:
Right to be informed:
You may receive information at any time concerning data identifying Holiday Partner Ltd in relation to the personal data provided by you, as well as about:'
o the company employee – responsible for the protection of personal data;
o the intention of Holiday Partner Ltd to submit your data to third parties;
o the period for storage of your data;
o the existing of automated decision-taking;
o information about the rights you have, including the right to complaint to the Supervisory body – The Commission on personal data protection.
Right to access to own personal data:
You are entitled at any time to request information on whether your personal data is stored. You can contact Holiday Partner Ltd using the contacts provided in the present policy.
Right to transferability:
Holiday Partner Ltd processes your personal data on the grounds of your consent, you are entitled to receive a copy of your data in a structured, commonly used and suitable for machine reading format. You are entitled to request transfer of your data to another personal data administrator whenever possible. All these rights are limited to the personal data you have provided to us.
Right to correction:
You are entitled to request correction of your personal data if it is inaccurate, as well as to supplement your personal data.
Right to deletion:
You are entitled to request deleting of all your personal data stored by Holiday Partner Ltd at any time, except in the following situations:
*you are currently in the process of communication with the Customer Service Department
*you have made a purchase
*if you have made a purchase, we will retain your personal data in relation to specific laws requiring us to do so.
The right to object against processing on the grounds of legitimate interest:
Upon an objection by you, Holiday Partner Ltd is obliged to terminate processing unless it proves there are legal grounds for such processing having priority before the interests, rights and liberties of a data subject, or for the ascertaining, exercising or protection of legal consequences.
Right to object to direct marketing:
You have the right to object to receiving marketing messages, including against profiling and analysis for the purposes of direct marketing. In the event of an objection in relation to the previous sentence, the processing of your personal data will be terminated.
You can exercise your right to refuse direct marketing in the following manners:
* by following the instructions in each message sent with a marketing purpose;
* by editing the settings in your profile;
How can you apply your rights?
We treat the protection of personal data very seriously. You can always contact us at firstname.lastname@example.org
Obligations of Holiday Partner Ltd and measures undertaken in relation to the storage of your personal data:
o Holiday Partner Ltd has appointed an employee for protection of personal data whose contact details you can find below in the present policy;
o the processing of data is based on all principles determining the outlook of the General Data Protection Regulation (ЕС) 679/2016;
o Holiday Partner Ltd keeps a register of activities of the processing of personal data;
o Holiday Partner Ltd assists in exercising the rights of the data subjects in the manners specified in this policy;
o Holiday Partner Ltd manages the risk related to personal data protection in compliance with the General Data Protection Regulation (ЕС) 679/2016
Employee on protection of personal data:
We appointed a responsible person for the protection of personal data, in order to guarantee that your personal data will always be processed in a correct and legitimate manner. You can contact our employee responsible for the protection of personal data on email@example.com
Right to file a complaint to a supervisory body:
If you believe that we are processing your personal data in an incorrect manner, you can contact us. You are also entitled to file a complaint before the Commission on Protection of Personal Data using the contacts herein above
9. Transfer of personal data to third countries:
In case we transfer your data to third countries, this is performed only pursuant to the conditions of the General Data Protection Regulation (ЕС) 679/2016. For countries in relation to which the European Commission has determined they ensure adequate level of data protection, such transfer can take place without an additional permission being necessary.
In the event of absence of a decision related to an adequate level of protection concerning the transfer of data to a third country, we will transfer data after you have been informed of the possible risks related to such transfer, due to the absence of a decision as to the adequate level of protection and of appropriate guarantees for the relevant tihrtd country and you have explicitly provided your consent therefor, or when this is required as a result of the performance of conditions of a contract between the data subject and Holiday Partner Ltd, or such transfer is necessary in order to enter into or perofrm a contract signed in the uinterest of the data suibject between Holiday Partner Ltd and another natural person or legal entity.