Privacy policy
Introduction
Stodi tex SD EOOTo respect your privacy and is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website (regardless of where you visit it) or when you otherwise provide us with personal data by other means (such as over the phone) and tell you about your rights to privacy and how the law protects you.
This privacy notice is provided in a multi-layered format so that you can easily click through to the specific areas listed below. Alternatively, you can download a pdf version of the policy here.
Please also refer to the glossary we have set out at the end of the Policy if there is any terminology used in this privacy notice that you are unfamiliar with or do not fully understand.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW YOUR PERSONAL DATA IS COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- HOW WE DISCLOSE YOUR PERSONAL INFORMATION
- WHEN WE TRANSFER YOUR DATA TO A PARTNER
- HOW WE PROTECT YOUR DATA
- HOW LONG WE KEEP YOUR DATA
- YOUR LEGAL RIGHTS
- DICTIONARY
1. Important information and who we are
Purpose of this privacy notice
This privacy notice is intended to give you information on how Stodi tex SD WellLtd. collects and processes your personal data, including any data you may provide through this website or by other means (such as by telephone) when you make an inquiry with us, when you book a villa, when you register for our newsletter, when you participate in competition etc.
This website is not intended for children and the only circumstances in which we collect data relating to children is when you book a villa and you have children in your party.
It is important that you read this privacy notice together with any other privacy notice or fair handling notice we may provide in certain cases where we collect or process personal data about you so that you are fully aware of how and why we use your data . This privacy notice supplements the other notices and is not intended to supersede them.
Administrator
„Stodi tex SD EOOD” is the controller and responsible for your personal data (collectively “Stodi tex SD .“ "Amethyst Villas", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing matters relating to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Contacts
Our full details are:
Full name of the company: Stodi tex SD EOOD
Name of the person responsible for personal data: Stoyan Ivanov
Email address: amethystluxuryvillas@gmail.com (to opt out of marketing materials)
Postal address: Sofia 1304, .
Telephone: + 359 885 42 00 16
You have the right to lodge a complaint at any time with the Office for the Protection of the Commissioner, Bulgaria's data protection supervisory authority. However, we would appreciate the opportunity to address your concerns before you approach the CPO, so please contact us first.
Changes to the privacy notice and your obligation to inform us of changes
Тази версия е актуализирана последно на 01.07.2024 and historical versions can be obtained by contacting us.
It is important that the personal data we store about you is accurate and up-to-date. Please inform us if any of the data you provide us should change during your relationship with us.
Third Party Links
This website may include links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data or personal information means any information about an individual from which that individual can be identified. It does not include de-identified data (anonymized data).
We may collect, use, store and transfer different types of personal data about you, which we have grouped as follows:
(A) Identity Information
This includes data specifically related to your identity, such as your first name, maiden name, surname, marital status, title, date of birth and gender.
(B) Contact Information
This includes data related to how you can be contacted, such as billing address, shipping address, email address and telephone numbers.
(C) Financial Data
This includes data relating to your funds and payment methods, such as your bank account and payment card details.
(D) Transaction Data
This includes data relating to transactions you have made with us, such as details of payments to and from you and other details of products and services you have purchased from us.
(E) Technical data
This includes more technical data that we may receive when you use our website, such as your Internet Protocol (IP) address, your login details, browser type and version, time zone setting and location, plug-in types and versions for browser, operating system and platform and other technologies of the devices you use to access this website.
(F) Profile Data
This includes the data we receive when you create an account on our website and use this policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(G) Usage Data
This includes information about how you use our website, products and services.
(H) Marketing and Communications Data
This includes your preferences regarding whether you want to receive marketing from us and our third parties and your communication preferences.
We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data by law, as it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a particular website feature. However, if we combine or link aggregated data with your personal data in a way that can directly or indirectly identify you, we will treat the combined data as personal data, which will be used in accordance with this privacy notice.
Special categories of personal data
We collect the following special categories of personal data about you.
Details of your:
• race and/or ethnicity.
We collect and process the above data only when strictly necessary to provide the travel service you have purchased. In addition, we will only collect and process the above special categories of sensitive personal data when you have provided us with your express consent to do so.
You are under no obligation to consent to us processing your sensitive personal data. However, without your consent, we will not be able to make the necessary arrangements to provide the travel services you have booked or are trying to book. As a result, if you do not provide your consent, we will not be able to proceed with your booking.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and cancellations in clause 23 of our Booking Terms and Conditions will become payable.
If you do not provide personal data
Where we are required to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
In other words, when we require details from you in order to provide you with the travel services you have chosen, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are trying to book.
In this case, depending on when you fail to provide the required date, we may either be unable to process your booking or may have to cancel your booking, in which case we will treat this as a 'cancellation by you' in compliance with our General Booking Terms and Conditions We will notify you if we are unable to process a booking or for this reason need to cancel a booking.
3. How your personal data is collected
We use a variety of methods to collect data from and about you, including through:
(A) Direct interactions
You may provide us with your personal, contact and financial information by completing forms or by contacting us by post, telephone, email or otherwise. This includes personal data you provide when:
• you make a reservation;
• making an inquiry about any of the services we offer;
• create an account on our website;
• subscribe to our newsletter or other publications;
• request that information be sent to you;
• participate in competitions, promotion, survey or..
• send us feedback.
(B) Automated Technologies or Interactions
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns.
We collect this personal data using cookies, server logs and other similar technologies. Please see our cookie policy for more details.
(C) Third Parties
We may receive personal data about you from various third parties as set out below:
• Technical data from the following countries:
(i) analytics providers such as Google based outside the EU.
• Contact, financial and transactional data from providers of technical, payment and delivery services, such as Coutts PLC, based in the EU.
• Identity and contact data from third-party social media or communication services (eg Google, Facebook, WeChat). This information varies and is controlled by this Service or as authorized by you through your privacy settings on this Service.
4. How we use your personal data
We will only use your personal data where the law allows us to. We will most often use your personal data in the following circumstances:
• When we have to perform the contract, we are about to enter into or have entered into with you.
• When you, as a Guest, submit a booking request, certain information about you is shared with the property manager of the accommodation you have booked, including your full name and passport details, which, according to Bulgarian law, must be registered by the manager with the local authorities. We will also request the full names and nationalities of all additional Guests to be shared with the manager and registered with the local authorities, as well as any other information you agree to share to facilitate your stay at the rented property, such as additional services like childcare requests, shopping, and cooking with your personal preferences, such as allergies.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• When we have to comply with a legal or regulatory obligation.
• Where, after staying at a property, you write reviews and ratings about the property and any services provided.
• If you submit a review through Airbnb, your feedback will be visible on our website and also visible on the Airbnb website, and both contents are again publicly visible
In general, we do not rely on consent as a legal basis for processing your personal data, except in connection with sending direct marketing communications to you by email. You have the right to withdraw your consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
Below, in table format, we have set out a description of all the ways in which we plan to use your personal data and which of the legal grounds we rely on to do so. We have also identified what our legitimate interests are where relevant.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we use your data. Please contact us if you require details of the specific legal basis we rely on to process your personal data where more than one basis is set out in the table below.
Marketing
We strive to provide you with choices regarding certain uses of personal data, particularly in relation to marketing and advertising.
Below we have set out the various means by which we aim to offer you the opportunity to make such a choice.
When you have consented to marketing, we:
• We send you if you are a repeat customer, meaning you have rented a villa with us in previous emails, reminding you of the 5% discount you are entitled to, news of events, new villas and other services.
• Send you a weekly email with promotional messages about new villas, special offers and news.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form an idea of what we think you might want or need, or what might be of interest to you. This is how we decide which products, services and offers may be right for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and in any event you have not opted out of receiving such marketing.
Third Party Marketing
We will obtain your express consent before sharing your personal data with a third party for marketing purposes.
Refusal
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at any time.
When you opt out of receiving these marketing communications, this will not apply to personal data that you have provided to us due to the purchase of travel services or other similar transactions.
Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become unavailable or may not function properly. For more information about the cookies we use, please see our cookie policy.
Changing the target
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where required or permitted by law.
5. Disclosure of Your Personal Data
We may need to share your personal data with the parties listed below for the purposes set out in the table in paragraph 4 above.
(A) Internal Third Parties as defined in the Glossary.
(B) External Third Parties, as defined in the Glossary.
(C) Specific third parties, such as:
1. local police and local courts where you have booked a property with us and we are therefore legally required to disclose your details to such parties.
Similarly, we may have a legal obligation to disclose your personal data to the local authorities in the area where you have booked one of our properties in order to facilitate the collection and remittance of tourist taxes by the property manager.
(D) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire or merge with other businesses. If a change occurs in our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and we only allow them to process your personal data for specified purposes and in accordance with our instructions.
6. International translations
Many of our external third parties are based outside the European Economic Area (EEA), so their processing of your personal data will involve data transfers outside the EEA.
Whenever your personal data is transferred outside the EEA, we ensure that it is afforded a similar level of protection by ensuring that at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission has assessed as providing an adequate level of personal data protection. For further details, see For more details, see European Commission: Adequacy of personal data protection in non-EU countries.
- When we use certain service providers, we may use certain contracts approved by the European Commission that give personal data the same protection as it has in Europe. For further details, see European Commission: Sample contracts for the transfer of personal data to third parties.
- When we use US-based providers, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For more details see European Commission: EU-US Privacy Shield.
Please contact us if you would like further information about the specific mechanism used by us when transferring your personal data outside the EEA.
7. Data Security
We have implemented appropriate security measures to prevent accidental loss, misuse, unauthorized access, alteration, or disclosure of your personal data. Additionally, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data in accordance with our instructions and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected personal data breach, and we will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long will you use my personal data?
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and applicable legal requirements.
Details of retention periods for various aspects of your personal data are available on request by contacting us.
In addition to the above, we are required by law to retain basic information about our customers (including contact, identity, financial and transactional data) for six years after they cease to be a customer for tax purposes.
If you book with us, we will retain your information for 6 years after the completion of your reservation (for adults) or 6 years from the date of your 18th birthday (for children traveling under the reservation) to allow us to defend any legal claims you may bring against us. In certain circumstances, you may request that we delete your data: see the section on the Right to Erasure below for more information.
In some circumstances, we may anonymize your personal data (so that it can no longer be linked to you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
You have the right to:
– Access request
to your personal data (known as a "data subject access request"). This allows you to obtain a copy of the personal data we hold about you and to check whether we are processing it lawfully.
– Request a correction
of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to check the accuracy of new data you provide to us.
– Request to delete
This allows you to request that we delete or remove personal data when there is no valid reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data when you have successfully exercised your right to object to processing (see below), when we may have processed your information unlawfully, or when we are required to delete your personal data to comply with local law. Please note, however, that we may not always be able to fulfill your deletion request due to specific legal reasons, which will be communicated to you, if applicable, at the time of your request.
– Object to process
You have the right to object to the processing of your personal data when we are relying on a legitimate interest (or those of a third party) and there is something about your specific situation that makes you want to object to processing on this ground, as you feel it impacts your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
– Request restriction of processing
of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios:
(a) if you want us to ascertain the accuracy of the data;
(b) where our use of the data is unlawful but you do not want us to delete it;
(c) when you need us to store the data, even if we no longer require it, because you need it to establish, exercise or defend legal claims; or
(d) you have objected to us using your data, but we need to check whether we have overriding legitimate grounds for using it.
– Request the transfer
of your personal data to you or to a third party. We will provide you or a third party you have chosen with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you have initially given us consent to use or where we have used the information to perform a contract with you.
– Withdraw consent at any time
where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.
There is usually no fee required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unreasonable, repetitive or excessive. Alternatively, we may refuse to fulfill your request in these circumstances.
What we might need from you
We may need to request specific information from you to help us verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to a person who is not entitled to receive it. We may also contact you to ask for additional information regarding your request to expedite our response.
Deadline for response
We try to respond to all legitimate requests within one month. Sometimes it can take us more than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
10. Glossary
LEGAL BASIS
– Legitimate interest
This means that our business interest in running and managing our operations allows us to provide you with the best service and a secure experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests outweigh the impact on you (unless we have your consent or it is otherwise required or permitted by law). You can obtain additional information about how we assess our legitimate interests against potential impacts on you regarding specific activities by contacting us.
– Execution of the contract
means processing your data when necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
– Comply with a legal or regulatory obligation
means processing your personal data where necessary to comply with a legal or regulatory obligation to which we are subject.
– External third parties
1. Travel service providers acting as processors based in Bulgaria who provide the services that make up each booking you make with us.
2. MAILCHIMP. Based in the USA, acting as a processor for the purpose of sending our photos by post.
3. Bulgarian regulators and other authorities acting as processors or joint controllers based in Bulgaria who require reporting of processing activities under certain circumstances.