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Privacy Notification for Visitors to Accommodation Sites

Privacy Notification for Visitors to Accommodation Sites

Herein Sopharma AD (JSC), UIC (Unified Identification Code) 831902088 (“Sopharma”, the “Company”) provides you with information about your personal data which may be processed at accommodation in the own of the Company accommodation sites:

-       Hotel Sopharma, town of Pomorie, Municipality of Pomorie;

-       Holiday base Sopharma, villa area Ovcharov Plazh (Shepherd’s Beach) – South, town of Balchik;

-       Guest house Dilyana and Elitsa, village of Vrabevo, municipality of Troyan;

-       Guest house No 1, guest house No 2 - , village of Vrabevo, locality of Derzhika, municipality of Troyan;

-       Holiday base Sopharma, town of Boboshevo, municipality of Boboshevo.

Data about the personal data controller.

Sopharma is with headquarters and address city of Sofia, zip code 1220, district of Nadezhda, 16, Iliensko Shose Street. You may contact the personal data protection official Law Firm Ernst and Young, e-mail address: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

This Notification aims at rendering you assistance to realize why and how we may use your information. The lists and the examples herein below are illustrative and are not fully representative of each data subject.

What your personal data do we process?

“Personal data” means any information about you, which you could be identified from, inclusive of information which may be protected in conformity with the applicable national and European legislation.

The personal data of the visitors which Sopharma usually processes are as follows:

Categories of personal data


Grounds for processing

Data needed for the reservation

Name, contact telephone

Fulfillment or pre-contractual and contractual obligations

General data

Three names, date of birth, gender, citizenship, address

On the grounds of the legal obligation of the controller under the Tourism Act and the Local Taxes and Fees Act

Identification data

PIN/PFN (Personal Foreigner’s Number)

Data from an identity paper

Number of identity card, a valid national identity document, a state which issued the national document

Data about stay

Date of arrival and departure from the site

Data from the systems for security and control over the access -

(applicable for the sites which have the indicated systems)

Records from video monitoring

Legitimate interest of the controller to provide your safety

Other data

Other data which may be collected in connection with a tourist visit to a hotel / a guest house / a holiday base managed by Sopharma

Fulfillment of pre-contractual and contractual relationships, a legal obligation, a legitimate interest and/or consent

Purposes which we process your personal data for

The personal data provided by you shall be used for the purposes of administration of the hotel service, inclusive of but not limited to:

-          Realization of reservation and servicing

-          For the purposes of the provision of the accommodation related service;

-          Administration and keeping registers for accommodation;

-          For the purposes of fulfillment of legal obligations and requirements of regulatory authorities.

Whom can we share your personal data with?

Sopharma respects and keeps the confidentiality of your personal data. With observation of the legal requirements Sopharma may disclose your personal data to the following persons:

-        Providers of services: When we use providers of services related to technical maintenance of internal information systems and operational maintenance of our activity, it is possible that the Company should disclose personal data. Similar disclosure of data shall be made only with the availability of a well-grounded reason for the purpose and on the grounds of an agreement in writing of the recipients to provide an adequate level of protection;

-        State and municipal authorities: In fulfillment of its legal obligations, the Company may be obligated to disclose your personal data with an explicit instruction of state or municipal authorities (the Ministry of Interior, the Ministry of Tourism, local state authorities, whose territory the accommodation site is located on). At disclosure of personal data to state authorities we shall strive to cooperate with these authorities at their enquiries but we shall also strive to respect the rights and the inviolability of your private life in so far as possible;

What periods do we store your personal data for?

We store your personal data in conformity with the Policy for Storage, Archiving and Destruction of Documents in Sopharma AD. Your personal data shall be stored by the Company only for the period needed for the attainment of the objectives, which the personal data were initially collected for, unless the law requires that the Company should store them for a longer period of time.

Security of your personal data

Sopharma maintains appropriate administrative, technical and organizational measures designated to render assistance to the preservation of the security and the inviolability of the personal data of the visitors and to protect them from accidental or unlawful destruction, loss, non-permitted rectification, disclosure or access, misuse and any other illegal form of processing.

For the fulfillment of its obligations for protection of your personal data, Sopharma duly reports the achievements of the technical progress. Sopharma introduced procedures for security as well as technical and physical limitations for access and use or personal data.

Sopharma conducts trainings of its employees pertaining to the policies and the procedures for protection of the personal data.

Your rights with regard to your personal data

With observation of the Bulgarian legislation, you have the following rights in connection with your personal data processed by Sopharma:

  1. To receive access to your personal data which Sopharma processes and to receive a copy of them;
  2. In event of incompleteness or inaccuracy in the data Sopharma processes that your personal data should be rectified;
  3. To request that your data should be erased when the conditions for that are available at hand. Such events are if the purpose, which the data are collected for, is attained; you have withdrawn your consent when the processing is based on consent and there are no other legal grounds for processing; your data are not processed in conformity with the law and so on;
  4. In the events stipulated by the law to require that the processing of your personal data should be restricted;
  5. In the events stipulated by the law to make an objection to the processing of your personal data;
  6. To exercise your data portability right and to require that your data should be provided in a structured, commonly used and machine-readable format;
  7. To withdraw the consent provided by you when the processing of your personal data is based on consent.

You will find detailed information about the conditions and the procedure, which you may exercise your rights in, in the Rules for Exercise of the Rights of the Data Subjects of Sopharma on our Web site:

You also have the right to lodge a complaint to the Commission for Personal Data Protection  when the relevant prerequisites for that are available at hand.

How you can contact us?

In event that you have questions or complaints about this Privacy Notification or the manners and the purposes we use your personal data for, you may contact us at the following address: city of Sofia, zip code 1220, district of Nadezhda, 16, Iliensko Shose Street, electronic mail: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Our personal data protection official is Law Firm Ernst and Young, email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Updating the Privacy Notification

This Notification may be periodically updated also without a notice to reflect the alterations in the practices for protection of the personal data of Sopharma. You may get acquainted with the topical Rules for protection of personal data processed at the provision of hotel services by Sopharma AD on the spot in the relevant accommodation site.