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Puna Child
Booking

PRIVACY POLICY

Contact information for the Supervisory Authority
Commission for Personal Data Protection
Address: Sofia, P.C. 1592, 2 Prof. Tsvetan Lazarov Blvd.
Website: www.cpdp.bg

It is advisable to take the time to familiarize yourself with this Privacy Policy and to review it periodically, because we may change it at some point.

1. Scope

The protection of your personal data is a high priority for “CHERNO MORE HMG” AD. This Privacy Policy explains how “CHERNO MORE HMG” AD collects, stores, processes, protects, uses and disseminates personal and other data collected about you in writing, orally, electronically or while you use the websites (together with any other and any future website, collectively referred to as the “Website”). Our personal data protection practices are in accordance with the applicable Bulgarian data protection legislation and with 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.

2. Basic definitions

For the purposes of this Privacy Policy, the following terms are used:

Personal data is any information related to an identified person or a natural person who can be identified, including, but not limited to: (a) first name or initial and last name; (b) personal identification number; (c) permanent or current address; (d) telephone number; (e) e-mail address or online identifier associated with the person; (f) data regarding financial status, health status or data regarding professional experience; (g) behavioral or demographic characteristics when linked to personal identifiers; (h) voice data and video image; or (i) any other information relating to a person which is combined with any of the above.

Other data, as defined by the applicable law, which may be anonymized and/or aggregated information, as well as any other information that does not reveal the identity of the person or is not directly linked to them. Other data may include, but is not limited to: cookies, IP address and information obtained from the IP address, information contained in HTTP headers. Other data stored in internet protocols, browsers or different devices, operating systems and information used by “APPS” applications of your mobile device, screen resolution, behavioral data about your use of the sites and preferred languages.

Processing of personal and other data means any operation or set of operations performed on personal or other data by automated or other means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

Sensitive personal data is a type of personal data which may include, but is not limited to, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

Suppliers of goods and services are third parties that we use under contractual relations to fulfill our legal obligations and carry out our business activity and to provide you with many of our services, functions and aspects of the Website.

3. What personal and other data we collect

Our privacy policies depend on the type of relationship you have with “CHERNO MORE HMG” AD and on legal requirements. We strive to collect personal and other data only to the extent necessary to provide you with products, services or information you have requested or to recruit the staff necessary for the normal functioning of the Company. We may use the information to improve functionality when using our Website, in accordance with this Privacy Policy. Below are the grounds and some of the ways in which we collect and use information.
Your personal data may also be collected in connection with Customer Programs and games organized by “CHERNO MORE HMG” AD. Each Customer Program and Game has its own individual terms, with a detailed description of the participation rules, prize pools, the personal data required that will be collected, the methods of collection, retention periods and purposes of processing.
When organizing such Customer Programs and games, “CHERNO MORE HMG” AD also complies with the general personal data protection rules defined by the specific social platform where the Game is distributed. Usually, but not only – Facebook, Twitter, Instagram.

3.1. Users

“CHERNO MORE HMG” AD collects user data in various ways. In all cases, we collect only the personal data that you have voluntarily provided to us and we do not collect any other data that has not been provided to us without your voluntary consent.

3.1.1. Personal data you have voluntarily provided

You may choose to communicate with us and provide personal data such as your:
• names, postal and e-mail address, telephone and/or mobile number, city, postal code, age, bank account and other information.

3.1.2. For what purpose we use your personal data

“CHERNO MORE HMG” AD uses the above-described data when provided by Users in cases of:

  1. performance of a contract concluded with a client, including delivery of goods and services;

  2. submission by clients of opinions, complaints, proposals, objections, etc.;

  3. customer satisfaction surveys;

  4. providing a response;

  5. connecting to the Wi-Fi network provided by the restaurants and accommodation facilities of “CHERNO MORE HMG” AD;

  6. contacting us by phone, e-mail or post with a question, recommendation or complaint;

  7. responding to your inquiries and complaints related to the quality of the goods offered;

  8. in connection with Customer Programs and in case you are a winning participant in the Games organized by “CHERNO MORE HMG” AD.
    “CHERNO MORE HMG” AD does not collect personal data from its clients unless they contact us directly. In order to respond adequately to clients’ inquiries, it is possible that personal data may be shared with third parties.

3.1.3. Other data collected automatically

We collect data automatically through the Website. However, if we combine your personal data with the data we collect automatically (e.g. geographic location from your IP address and combine it with behavioral information about your use of the Website, with your name) we treat the information as personal.
“CHERNO MORE HMG” AD and its online advertising and marketing partners may use various technologies to collect information, including:

3.1.4. Cookies

Like many other websites, we use devices that collect data, such as “cookies”. We collect this data in order to analyze traffic to our page and to measure the effectiveness of the promotions we offer. A cookie is a text string of information that the Website sends to the cookie file of the browser on the hard drive of your computer so that the Website can remember you.
The cookie usually contains the name of the domain from which the cookie came, the “lifecycle” of the cookie and a value which usually represents a randomly generated unique code.
This helps us provide you with better use of our Website and also allows us to improve the services we offer.
A few important things you should know about cookies:
“CHERNO MORE HMG” AD offers certain functions that are available only through the use of cookies.
• they are used to improve the use of the Website.
• most cookies are “session cookies”, which means they are automatically deleted from your hard drive at the end of the session.
You have the option to accept or refuse cookies by changing your browser settings. If you refuse cookies, this may prevent you from using all interactive features of the Website.

3.1.4. Internet Protocol (“IP”) Addresses

The IP address is associated with your computer or your mobile device. “CHERNO MORE HMG” AD may use your IP address to help diagnose problems with the “CHERNO MORE HMG” AD server, administer the Website and maintain contact with you while you use the Website.

3.2. Potential employees

If you wish to be part of the team of “CHERNO MORE HMG” AD and submit an application for employment or attach your CV, we process and store the personal data contained in the specified documents for a period not longer than 6 months after the completion of the selection process. The collected personal data may include, but is not limited to:
• Identification: names, address, telephone number, e-mail address, date of birth, citizenship, bank account;
• Education and professional qualification: data related to education, work experience, professional and personal qualification and skills, when necessary and required for the position.
This personal data is stored in accordance with the personal data privacy rules provided when applying for work at “CHERNO MORE HMG” AD.

3.3. Employees

With regard to its employees, “CHERNO MORE HMG” AD processes the following personal data:
• Identification: three names, personal identification number, date of birth, permanent address, education and professional qualification; professional experience, bank account number;
• Data regarding health status, including a medical certificate for all employees and data from the personal health books of employees working directly with food;
• Data concerning criminal record – certificate of criminal record.
This personal data is stored in accordance with the internal rules for personal data protection of “CHERNO MORE HMG” AD and the Privacy Notice for employees’ personal data.

3.4. Counterparties and suppliers

With regard to our suppliers of goods and services who are natural persons / as freelancers / and the representatives or contact persons of our suppliers of goods and services who are legal entities, “CHERNO MORE HMG” AD processes the following personal data:
• Identification: names, personal identification number, address, telephone number, e-mail address, date of birth;
• Professional activity: position, official capacity;
This personal data is stored in accordance with the internal rules for personal data protection of “CHERNO MORE HMG” AD and the Privacy Notice for suppliers and partners.

3.5. Visitors to premises

With regard to persons who visit premises of “CHERNO MORE HMG” AD where video surveillance is carried out, “CHERNO MORE HMG” AD processes the following personal data:
• Identification: voice data and video image;
This personal data is stored in accordance with the personal data protection rules for video surveillance and monitoring of “CHERNO MORE HMG” AD.

4. How we collect the data

Clients

The Company usually collects and processes clients’ personal data when preparing, drafting and providing a reservation and accommodation at the facilities of “CHERNO MORE HMG” AD.
The Company usually does not process clients’ personal data when preparing and selling drinks and food in its establishments.
Clients’ personal data is processed when a client decides to participate in one of the programs or games organized by the Company. In such a case, clients’ personal data (the processed personal data may include, depending on the specific case, the client’s first and last name, current address, e-mail address, date of birth, telephone number, payment data and, where applicable, information about the order and places of purchase) is processed only with the client’s consent, provided voluntarily in accordance with the rules of the respective program and game.
Clients’ personal data is processed within customer programs for the purposes of facilitating the fulfillment of the orders of the respective client, for marketing (for example as part of the Company’s marketing campaigns, to provide information about new products, to deliver commercial messages of the Company or to notify the client about won prizes or other winnings) and for the purposes of tracking client satisfaction.
Clients’ personal data (the processed personal data may include, depending on the specific case, the client’s first and last name, current address, e-mail address, date of birth, telephone number, payment data and, where applicable, information about the order and places of purchase) is also processed in cases of contact by a client with the Company in connection with expressing opinions, complaints, proposals, objections, etc.

Website users

The Company uses cookies on its Website. Cookies provide faster and more efficient browsing of the Website and adjust the display of products and other content according to the personal interests and specific needs of the User. Cookies are used to collect aggregated anonymous statistical data, allowing understanding of how the Website is used and enabling optimization of its structure and content, as well as to provide certain functions of the Website and personalize advertising.
The Company uses two types of cookies – temporary (session) cookies and persistent cookies. Session cookies are used temporarily and are stored on the User’s device until he/she leaves the Website or closes the application (web browser). In contrast, persistent cookies remain on the User’s device for the time specified in the parameters of the respective cookie or until the User deletes them.
The information obtained through the use of cookies may be collected only for the purposes of mediation and performing certain user functions. This data is encrypted in a manner that prevents access by unauthorized persons.
Typically, the application used to browse the Website allows the storage of cookie files on the User’s device according to the initially set settings. This mode can be changed either by fully blocking cookies in the web browser settings, or by partially blocking them – in this case the User is notified each time the device stores cookies. More detailed information about the options and ways to manage cookies is available in the settings of the application (web browser).
The Website collects information about the User’s IP address (i.e. the number that uniquely identifies the network interface of the User’s computer network), the domain name, as well as the type of web browser and operating system. The purposes of processing this data are similar to those of cookies, which means that this data is used by the Company to collect statistical data for analyzing Website use and for personalizing advertising.
Users’ personal data is processed with consent voluntarily provided by the User by loading the Website or is otherwise expected in connection with the use of the Website.
Users’ personal data of those who register or send an inquiry on the website is processed with consent voluntarily provided by the User when registering or sending the inquiry.

Employees and Potential employees

The Company processes the personal data of employees and potential employees within the scope necessary for selection and hiring of staff and fulfilling legal obligations (e.g. the obligation to withhold or pay taxes, to keep files for the purposes of health and social insurance, etc.). The employee is obliged to provide this data to the Company. Failure to provide this data should be considered a violation of legal requirements by the employee and/or the Company and may lead to sanctions imposed by the competent state authorities.
The Company processes employees’ personal data separately from legal requirements only with their consent and as part of establishing the legitimate interests of the Company or the performance of the contract concluded by and between the Company and the employee, more specifically for the purposes of processing personal data in the CVs of job applicants in the Company, preparing advertising materials, managing the Company’s profiles on social networks, storing records of the use of the Company’s company cars, providing information about Company events, protecting the Company’s property (mainly the use of video surveillance systems) or when providing access for authorized persons to the Company’s premises.

5. What we do with the personal and other data we collect

First of all, we use the data you provide or that we collect to provide you with the products, services or information you have requested. We also use the data to improve functionality when using our Website.
It is possible that we may use your data to provide you with information regarding products or services that may be of interest to you. In order to be able to automatically address customer inquiries and to provide the services offered through our Website, it is possible that we share information with our service providers.

6. Choice

You have the right to opt out of certain use and disclosure of your personal data as set out in this Policy. Before disclosing sensitive data to a third party or processing sensitive data for a purpose other than the original purpose or a purpose subsequently authorized by you, “CHERNO MORE HMG” AD will make the necessary effort to obtain your explicit consent. Where consent for processing is required by law or contract.
If you participate in any promotion, the personal data you provide will be processed in accordance with the privacy rules applicable to that promotion, to the extent they differ from this Policy.

7. Where we store your personal data

All personal data sent and collected through the websites is stored on our servers, on shared servers, on the servers of other controllers or personal data processors with whom “CHERNO MORE HMG” AD has staff recruitment agreements, or on the servers of our suppliers of goods and services. By using our websites, you agree that we store your data at the specified locations.

7.1. Provision of data to third parties

The Company provides already processed personal data only to partners with established technical and organizational measures for data protection and fulfillment of other obligations arising from Regulation (EU) 2016/679 of the EU of 27.04.2016 and the Personal Data Protection Act regarding data protection. The Company’s partners have access to personal data only within what is necessary for the performance of their obligations. Therefore, in certain cases, the Company provides personal data to other companies and third parties that provide services to the Company related to hosting personal data on shared servers, managing loyalty program applications, ensuring payments for purchases from the Company and analyzing marketing research. The personal data of the Company’s employees is provided to the external accounting company that collects accounting and tax archives and payroll records of the Company and, in some cases, to companies providing services to the Company that allow Company employees to report cases of violations of legal provisions or in cases where the Company, its partners or its employees act unethically.
Under no circumstances does the Company provide personal data to third parties in exchange for payment.

7.2. Transfer of personal data to third countries

The Company may transfer personal data to countries outside the European Union and in certain cases to third countries (USA), regardless of whether there is a decision of the European Commission on the level of protection of personal data in these third countries equivalent to that existing in the European Union.
The transfer of personal data to other companies and third parties is carried out, if necessary, on the basis of a contract under which the recipient of personal data undertakes to maintain high standards of personal data protection (the transfer of personal data is based on the “standard clauses” for personal data protection pursuant to Article 46(2)(c) of the General Data Protection Regulation) and/or subject to the consent of the person whose personal data is transferred.

Retention period. The personal data you provide will be stored for a period no longer than necessary to achieve the purposes for which it is processed.

8. How we protect your data

“CHERNO MORE HMG” AD applies organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of personal data processing.
Among other things, such security measures include the following activities:

  • “CHERNO MORE HMG” AD has established requirements for processing, registration and storage of personal data with internal procedures, compliance with which is monitored continuously;

  • employees’ access to personal data and permission to process personal data in the database of “CHERNO MORE HMG” AD is limited depending on their duties;

  • “CHERNO MORE HMG” AD has established confidentiality obligations for its employees;

  • access to the office equipment of “CHERNO MORE HMG” AD and the computers of each employee is restricted.

  • we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as best practices from international standards

  • for maximum security in processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.
    The security measures we apply are subject to continuous improvement and adaptation to state-of-the-art technologies.

9. Access

Where the law permits, you may use any of the methods in Section 13 of this Policy to obtain confirmation that “CHERNO MORE HMG” AD processes personal data about you and to request access, correction or deletion of personal data processed by us, including where the data has been processed in violation of the principles of Regulation (EU) 2016/679 of the EU of 27.04.2016 and the Personal Data Protection Act. Such requests will be processed in accordance with the internal rules of “CHERNO MORE HMG” AD, in compliance with Regulation (EU) 2016/679 of the EU of 27.04.2016 and the Personal Data Protection Act.
“CHERNO MORE HMG” AD respects and takes due care to comply with the rights of data subjects, but there may be cases where it is impossible to provide the requested information, including but not limited to:

  1. when the law takes precedence over the rights of the data subjects;

  2. when it would pose a risk to the security of the data subjects;

  3. when it would interfere with the privacy of other persons or where it is proprietary business information.
    If the Controller determines that access should be restricted, in each specific case “CHERNO MORE HMG” AD will make the necessary efforts to notify you of the reasons leading to the restriction of access to the information you requested, and will provide you with contacts for further inquiries.
    If necessary, the Data Protection Officer of “CHERNO MORE HMG” AD will contact another person who will cooperate and complete the process of providing the data you requested. In order to protect your data, the Controller will take the necessary steps to confirm your identity before granting access to, or making any changes related to, your data.

10. Data integrity – purpose limitation

“CHERNO MORE HMG” AD processes the personal data it receives while you use the sites or as long as necessary to complete the purpose(s) for which it was collected, including but not limited to: until completion of the services provided, for dispute resolution, for legal defense, when conducting audits, in the presence of legitimate business interests, for the performance of agreements and for compliance with applicable laws. Your consent for these purposes is not required.

11. Further sharing

“CHERNO MORE HMG” AD does not provide personal data to third parties unless a client or potential employee requests or has given consent for such disclosure, or disclosure is required by law. The Controller may share personal data with its service providers, consultants and affiliates for internal, business purposes or to supply you with a product or service you have requested.
Payment information will be processed only to fulfill the order; it may be stored by our service provider for the purposes of future orders or for accounting reporting needs.
The Controller requires from its suppliers or other personal data processors written consent for confidentiality and for ensuring protection of personal data maintained on behalf of the Controller, including ensuring at least the minimum level of protection required by the principles of Regulation (EU) 2016/679 of the EU of 27.04.2016; the data must not be used for any purposes other than those determined by the Controller. Suppliers must notify the Controller if they have found that they can no longer fulfill their obligations. With regard to further transfers of data provided to third parties, the Controller monitors the manner of processing of personal data by requiring assurance from the processing party that it complies with the principles of Regulation (EU) 2016/679 of the EU of 27.04.2016.
Your personal data is considered an asset of the company and may be disclosed or transferred to a third party in the event of a change in the legal and organizational structure of “CHERNO MORE HMG” AD, for example in any reorganization, sale, merger, division, joint venture, transfer, consolidation or other type of acquisition, disposal, or financing of all or part of our business, or of certain business assets or shares (including in connection with insolvency or similar proceedings). In such cases, your data is transferred to a third party so that you can continue to receive the same products and services or to maintain the same relationship with the third party.
Although we make every effort to maintain the confidentiality of the personal data we collect, “CHERNO MORE HMG” AD reserves the right to disclose personal data to third parties under certain limited circumstances, including: (a) compliance with law, search warrant, subpoena, judicial proceeding, court or administrative order; (b) response to a legal request by public authorities, including for the fulfillment of national security requirements or law enforcement requirements; (c) enforcement of the Controller’s policies or agreements; (d) collection of amounts due; (e) protecting users of the sites from fraud or abuse; (f) during emergencies where safety is at risk, as determined by the Controller; (g) where necessary for the establishment, exercise or defense of legal claims.
At the Controller’s discretion, server logs may be reviewed for security purposes, for example to detect unauthorized activity on the sites. In these cases, server data containing IP addresses will be shared with law enforcement agencies so that they can identify users in connection with their investigation of unauthorized activities.

12. Security

Although there is no such thing as “guaranteed security”, we and our partners use commercially reasonable measures (including all steps required by applicable law) designed to protect your personal information from loss, unauthorized access, use, alteration, disclosure or other misuse.

13. Rights of data subjects

You may also file a complaint with your Supervisory Authority; for Bulgaria this is the Commission for Personal Data Protection, at the addresses indicated in this Policy. “CHERNO MORE HMG” AD will fully comply with the recommendations given by the Supervisory Authorities and will take the necessary steps to remedy any non-compliance with regulatory principles.
Commission for Personal Data Protection,
address: Sofia 1592, 2 “Prof. Tsvetan Lazarov” Blvd.;
website: www.cpdp.bg.
If you suspect a violation of legal requirements, you have the right to file a complaint with the supervisory authority for personal data protection.

Your legal rights are:
• To request information as to whether we process your personal data, what it is and for what purpose it is processed.
• To request access to your personal data (“Data access request”). This allows you to receive a copy of the personal data we hold about you and to check that we process it lawfully.
• To request correction of your personal data held by us. You have the possibility to correct any incomplete or inaccurate information we hold about you.
• To request deletion of your personal data. This allows you to ask us to delete or remove personal data if:

  • the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

  • you withdraw your consent on which the processing is based and there is no other legal ground for processing;

  • the data subject objects to the processing, including profiling, and there are no overriding legitimate grounds for processing, or the data subject objects to processing for direct marketing purposes;

  • the personal data has been processed unlawfully;

  • the personal data must be erased for compliance with a legal obligation under Union law or Bulgarian law;

  • the personal data was collected in connection with the offer of information society services.
    • To object to processing against certain types of processing, such as direct marketing (unsolicited advertising messages), as well as where processing is based solely on the legitimate interest of the Controller.
    • To object to automated decision-making, including profiling, i.e. not to be subject to any automated decision-making by us using your personal data or profiling.
    • To request restriction of processing of your personal data when:

  • you contest the accuracy of the personal data, for a period enabling the Controller to verify the accuracy of the personal data;

  • the processing is unlawful, but the data subject does not want the personal data to be erased and requests instead the restriction of its use;

  • the Controller no longer needs the personal data for the purposes of processing, but the data subject requires it for the establishment, exercise or defense of legal claims;

  • you have objected to processing based on the legitimate interest of the Controller, pending verification whether the legitimate grounds of the company override those of the data subject.
    • To request transfer of your personal data in electronic and structured form to you or another person (commonly known as the right to “data portability”). This allows you to receive your data from us in a suitable electronic format and to transfer it to another person in a suitable electronic format.
    • To withdraw your consent. In the rare cases where you may have given consent for the collection, processing and transfer of personal data for a specific purpose, you have the right at any time to withdraw your consent regarding that specific type of processing. After we receive notification that you have withdrawn your consent, we will stop processing your information for the purposes for which you originally consented, unless there is another legitimate reason for us to do so by law.
    The request may be made by completing a Request Application and sending it to the e-mail address of the Data Protection Officer or to the address of “CHERNO MORE HMG” AD.
    In order to ensure that we have identified the correct person, we may contact you to confirm your request.
    “CHERNO MORE HMG” AD undertakes to consider your request without undue delay and in any case within 30 days of receiving the request. In cases involving legal and factual complexity, this period may be extended by a further 30 days. You do not need to pay a fee to exercise the above rights. In the event of a repeated request on the same grounds, if the request is manifestly unfounded or excessive, a fee may be charged.
    In order to provide complete, accurate and clear information in the Request, we may ask you for specific identifying data to help us confirm your identity. This is an additional security measure ensuring that your personal data will not be disclosed to persons who are not entitled to receive it.

14. Information concerning children

We do not knowingly collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person exercising parental responsibility for the child.
If you are a parent or legal guardian of a child whom you believe has provided us with personal data, please contact our data protection officer and they will take immediate action to delete the information in accordance with applicable law.

15. Links to third-party websites

Please note that the Website may contain links to other websites for your convenience and information. The Controller does not control external websites outside the company or their privacy practices. Please note that they may differ from those set out in this Policy. “CHERNO MORE HMG” AD does not endorse and makes no representations about third-party websites. Personal data that you choose to provide to websites not related to us is not covered by this Policy. We encourage you to review the privacy policies of other websites before providing your personal data. Some third parties may choose to share their users’ personal information with us. This sharing is governed by the company’s privacy policy, not by this Policy.

16. Changes to the Privacy Policy

The Controller may update this Privacy Policy. When changes are made, we will update the “last revision” date located at the top of the Policy.
If there are any changes to this Policy, we will notify you of them. We encourage you to read our Privacy Policy to stay informed about how we protect the information provided by you.
If you continue to use the Website after the publication or amendment of the Policy, this will be considered as your consent to be bound by it and all such changes thereto.
Any change to this Privacy Policy takes effect immediately upon its publication.

17. Other related policies

This Policy may be supplemented by one or more special policies or privacy notices. In the event of a conflict between this Policy and any special policy, the applicable special policy shall prevail.

In addition, you have the right to file a complaint with the Commission for Personal Data Protection: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., or electronically on the Commission’s website: https://www.cpdp.bg.

This policy is approved and enters into force as of April 2023.

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