Data Controller:

• Company Name: TEXTRON HOLIDAYS LTD
• UIC (EIK): 204590568
• Registered Office: Bulgaria, Sunny Beach Resort, Hotel Shipka
• Facility: Hotel Shipka (Categorization Certificate № [ENTER NUMBER])
• Contact: Any questions regarding this policy can be submitted via the Contact Form on the website.

The Hotelier processes the provided data in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679.

2.1. Categories of Data:

• Booking Data: First and last name, email address, phone number.
• Address Registration Data (Required by Law): Name, PIN/FIN, identity document data (number, date of issue/expiry), citizenship, and date of birth.
• Payment Data: Transaction information via EasyPay, bank transfers, or payment operators.
• Technical Data: IP address and cookies during website visits.

2.2. Purposes and Legal Grounds:

• Execution of a Contract (Art. 6, para. 1, b. “b”): To process your reservation, stay, and manage payments (including the 20% deposit).
• Legal Obligation (Art. 6, para. 1, b. “c”): Mandatory registration in the Unified Tourist Information System (ESTI) as per the Tourism Act.
• Legitimate Interest: Ensuring security within the hotel and analyzing website traffic.

3.1. Data Recipients:

Your data is provided to third parties only when legally necessary:

• Ministry of Tourism and Ministry of Interior (via the ESTI system).
• National Revenue Agency (NRA) and accounting services (for tax control purposes).
• Banking institutions for payment processing.

3.2. Retention Periods:

• Tourist Registers (ESTI): 5 years, as per the Tourism Act.
• Accounting Documents: 10 years, as per the Accountancy Act.
• Inquiries: Until the relevant communication is concluded.

4.1. Cookies:

The website uses cookies for analysis (Google Analytics) and the correct functioning of the reservation form. You can manage them through your browser settings.

4.2. Security:

We apply technical protection measures, including traffic encryption via SSL certificate and restricted access to administrative systems.

As our client, you have the following rights:

• Right to access and rectification of your data.
• Right to erasure (“Right to be forgotten”): Unless the data is required for a legal obligation (e.g., ESTI).
• Right to object to processing.
• Right to lodge a complaint with the CPDP (Sofia, 2 Prof. Tsvetan Lazarov Blvd.).

Changes: The Hotelier may update these rules by publishing the new version on the website.