Last Updated: June, 2018
This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Rosslyn branded hotels. Those entities include the companies Central Park Hotel Sofia EOOD and Keratech Engineering OOD. References to “we”, “us”, “our” and “Rosslyn Hotels” throughout this Privacy Notice, refers collectively to those legal entities.
What is Personal Information?
Personal information is any information about you as an identifiable individual. The personal information that we process includes:
Basic information – such as name, age, gender, passport information and passport photo;
Contact information – such as your home address, postal code, email address and phone number;
Financial information – such as your credit card details, itemized spending and transaction history;
Health information where disclosed and relevant to the provision of services;
Preferences – such as special requests, service issues and other preferences for your stay;
Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our mobile App); and
Correspondence – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.
How do we use your personal information?
We use your personal information for the following purposes:
to enable you to use our website and our mobile App with full functionality;
to help us identify you and any accounts you hold with us;
to provide personal customer service to you;
to assist us in making your reservation and providing the services you request at any of our properties;
to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;
for billing purposes in relation to your stay with us;
to confirm prior transactions and reconcile statements or invoices;
to contact you in relation to matters that arise from your request or stay with us;
to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);
to respond to a specific "Information Request" from you about one of our hotels and deal with any other enquiries, correspondence, concerns or complaints you have raised;
for you to participate in one of our on-line promotions;
to operate our business, including for internal purposes such as accounting, data analysis, statistical and research purposes and troubleshooting to help us improve our services.
On what basis do we use your personal information?
We use your personal information on the following basis:
to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;
to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;
for legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised to you, and to make your experience of our services more efficient and effective;
because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes;
for the establishment, exercise or defence of legal claims or proceedings.
How is personal information collected?
We collect your personal information while monitoring our technology tools and services, including emails sent to and from Rosslyn Hotels.
Otherwise, we gather information when you provide it to us, or interact with us directly, for example:
when you create a profile or sign in to access an existing profile on our website or App;
when you make a purchase through our website;
when you make a reservation online or by contacting a particular hotel or resort directly; and
during your stay at a hotel, including information provided during check-in.
We also receive information about you from other sources, such as our business partners and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.
How do we protect personal information?
We use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws. For example, we allow only encrypted communications from all of our web forms, including when you provide your credit card information through our website.
Each individual property operating under the Rosslyn Hotels brand stores personal information in a secure location and we take steps to ensure that only designated individuals have access to this information.
What information is not secure?
We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.
It is important to note that any e-mail communication is not secure. This is a risk related to the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (i.e. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information.
Finally, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer.
What personal information may be provided to third parties?
We may share certain of your personal information with:
other Rosslyn hotels;
third party service providers of Rosslyn Hotels who provide services to us to better serve your needs as our guest;
analytics and search engine providers that assist Rosslyn Hotels in the improvement and optimisation of the website, Booking Engine and our mobile App;
our professional advisors and auditors; and
local or foreign regulators, governments, courts, law enforcement and national security authorities.
Where a third party is engaged by Rosslyn Hotels to provide services on our behalf, Rosslyn Hotels ensures these parties protect your Personal Information in a manner consistent with the principles articulated in this Privacy Notice.
If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone.
If Rosslyn Hotels suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.
Accessing your personal information
We understand that you may like to know what personal information we hold about you. We are happy to assist you with your request. To protect your personal information, however, we require that you prove your identity to us at the time your request is made.
Where you make a request by other means, we request you contact us in writing via email, or letter including a copy of a government issued identification and signature. We require home and business addresses and phone numbers so we can check them with our files and be sure about your identity.
Rosslyn Hotels reserves the right to decline access to your personal information under certain circumstances as permitted by law. If your personal information is not disclosed to you, you will be provided with the reasons for this non-disclosure.
You may also be entitled to:
request the correction and/or deletion of your personal information in the cases in which we are not obliged by law to keep it;
request the restriction of the processing of your personal information, or object to that processing;
opt out from processing of your personal information for direct marketing purposes;
withdraw your consent to the processing of your personal information (where Rosslyn Hotels is processing your personal information based on your consent); and
request the receipt or transmission to another organisation, in machine-readable form, of the personal information you have provided to Rosslyn Hotels.
Where you are given the option to share personal information with Rosslyn Hotels, you can always choose not to do so.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
After you have chosen to withdraw your consent Rosslyn Hotels may be able to continue to process your personal information to the extent required or otherwise permitted by law.
If at any time you wish to exercise any of these rights, you can do so by contacting us:
via e-mail at firstname.lastname@example.org
via letter – to the attention of: Data Protection Officer, Rosslyn Hotels Group
5, Slavyanska Str., Sofia 1000, Bulgaria
How long is my Personal Information retained?
Your personal information will be stored for the period of time required by law. This may involve retaining information following your stay. We will delete your personal information once it is no longer required for any of the purposes described above.
We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Rosslyn Hotels.
If you have any questions or concerns regarding this Privacy Notice, please contact our Data Protection Officer by writing to the e-mail and post address above.