गोपनीयता नीति

Ostany तुम्हारे व्यक्तिगत डेटा को कैसे एकत्र, उपयोग और सुरक्षित करता है।

दस्तावेज़ “Privacy Policy” अंग्रेज़ी में दिखाया गया है। अंग्रेज़ी पाठ ही बाध्यकारी संस्करण है। बल्गारियाई अनुवाद

This Privacy Policy is drawn up in English, and the English text is the only authentic version. A Bulgarian translation is provided for convenience; in the event of any discrepancy, the English text prevails. Neither that translation nor any other, including an automatic translation by your browser, has legal effect of its own. This does not derogate from any mandatory rule of law on the language in which information must be provided to you.

Ostany: protection of personal data

Version: 1.2

Date of publication: [date]

Date of entry into force: [date]

This Policy explains what personal data we collect, why and on what legal basis we process it, to whom we disclose it, how long we retain it and what rights you have.

It has been drawn up in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and with the Bulgarian Personal Data Protection Act (Zakon za zashtita na lichnite danni).

The use of cookies is governed by a separate Cookie Policy: /legal/cookies-policy.

1. Who processes your data

1.1. Controller

Name	[FULL LEGAL NAME INCLUDING LEGAL FORM]
UIC (Unified Identification Code)	[UIC]
Registered seat and management address	[address]
Correspondence address	[address]
Email for data protection enquiries	[privacy@domain]
Telephone	[telephone]
Website	[domain]

1.2. Data protection officer

The Company has designated a data protection officer (DPO):

Name or position	[name/position]
Email	[dpo@domain]
Postal address	[address]

You may contact the DPO on all matters relating to the processing of your personal data and to the exercise of your rights under section 7.

1.3. Independent controllers

In addition to us, the following act as independent controllers in respect of your data:

Who	For what	Relationship to us
The Host with whom you have made a Booking	Performance of the stay, keeping the register of accommodated persons, submitting data to the Unified Tourist Information System (ESTI), collecting, declaring and paying the tourist tax, issuing documents	Independent controller. We transfer to the Host only what is necessary. The Host is responsible for its own processing.
Mollie B.V.	Payment processing, identification and verification under anti-money laundering legislation	Independent controller for payment and AML purposes. Policy: [link]
Competent authorities: the Ministry of Tourism, municipalities, the National Revenue Agency, the corresponding authorities in the other Member States	Compliance with legal obligations under Regulation (EU) 2024/1028, the Bulgarian Tourism Act (Zakon za turizma) and DAC7	Independent controllers upon receipt of the data
Google Ireland Limited (Ireland) and Google LLC (USA), when your browser loads the map picture on a listing page or an interactive Google map (see the Cookie Policy, section 4)	Providing the Google Maps service; Google's own purposes as described in its privacy policy	Independent controllers for their own purposes. Your browser sends them your IP address, browser and device data and the address of the Ostany page directly. For the map picture on a listing page, which your browser loads from Google when the map section comes into view or close to it, your browser sends the address of the Ostany website rather than of the page, and the request contains the location of the Property as shown in the Listing. Policy: [policies.google.com/privacy](https://policies.google.com/privacy)

There is no joint controllership within the meaning of Article 26 GDPR between us and the Hosts; each of us independently determines the purposes and means of its own processing.

Tourist tax, register of accommodated persons and ESTI. We do not collect, charge, declare or remit the tourist tax under the Bulgarian Local Taxes and Fees Act (Zakon za mestnite danatsi i taksi) or any equivalent tax or levy in another country, such as the Greek climate crisis resilience levy (Τ.Α.Κ.Κ.), and we process no personal data for the purpose of collecting, declaring or remitting it. To show you the price of your stay before you book, we multiply the rate of the tourist tax that the Host states by the number of persons and of nights of your Booking, and we keep that rate and the result with your Booking; this is part of the price information for your Booking (purpose B, section 3.1), not processing for the purpose of collecting, declaring or remitting the tax. Nor do we keep the register of accommodated persons under the Bulgarian Tourism Act or submit data on accommodated persons to the Unified Tourist Information System (ESTI), and we receive no such data from it. Where these take place, the Host carries them out as an independent controller, with the data you give the Host directly (for example your identity document details at check-in) and the Booking data we transfer to the Host for the performance of the Booking, under the Host's own responsibility, including for informing you under Articles 13 and 14 GDPR. Where we transmit data to competent authorities under purposes F and G (section 3.1), we do so only to comply with the obligations described there, and not for the purposes of the tourist tax.

2. What data we collect

2.1. Data you provide to us

Necessary for the use of the Platform:

Category	Specific data
Account and profile data	First name and surname, email address, telephone number, password (in hashed form), profile picture, date of birth, preferred language
Identity data (upon verification)	Image of an identity document, document number and validity period, nationality; where necessary, a selfie for comparison
Booking data	Dates, number and names of the guests, special requirements, messages with the Host
Payment data	Transaction identifier, last four digits of the card, type of payment instrument, amount, currency, date. Full card data is processed directly by Mollie and does not reach us.
Host data	Name, UIC, registered seat, details of the representative, bank account, details of the beneficial owners, tax identification number, VAT number, registration number of the Property, categorisation or registration document; for Properties in the Hellenic Republic, the ΑΦΜ (the Greek tax identification number) and an Α.Μ.Α. (Αριθμός Μητρώου Ακινήτου, the Greek property registry number) or ΜΗ.Τ.Ε. (Μητρώο Τουριστικών Επιχειρήσεων, the Register of Tourism Enterprises) number

Data you provide optionally:

Additional profile information (description, city, languages spoken), reviews and ratings, photographs and other content, messages to us and to other users, survey responses, data relating to accompanying persons.

When you provide data about another person, for example a fellow traveller, you confirm that you have a basis for doing so and that you have made that person aware of this Policy.

Special categories of personal data (Article 9 GDPR). As a matter of principle we do not collect special categories of personal data. In the following limited cases such data may be processed:

Case	Data	Basis
You voluntarily communicate dietary or health-related requirements in a message to the Host	Health data	Explicit consent: Article 9(2)(a) GDPR. You are not obliged to provide such data; you may communicate it directly to the Host upon check-in.
You communicate accessibility requirements	Data concerning disability	Explicit consent: Article 9(2)(a) GDPR
You bring a claim or a challenge in which you rely on a health-related reason	Health data	Establishment, exercise or defence of legal claims: Article 9(2)(f) GDPR

We do not use biometric identification. If in the future we introduce automated facial comparison in the identity verification process, this will take place only after your explicit separate consent, with a non-biometric alternative made available and following a data protection impact assessment under Article 35 GDPR.

Personal data relating to criminal convictions and offences (Article 10 GDPR) is neither collected nor processed.

2.2. Data collected automatically

Category	Specific data
Technical data	IP address, browser and operating system type and version (as sent by your browser), the language setting of your browser
Usage data	Searches you make and Listings you view while signed in, actions within the booking flow, dates and times of access
Precise location	Only through the mobile application and only after your explicit permission, which you may withdraw at any time from your device settings
Data from cookies and similar technologies	See the Cookie Policy
Security logs	Records of log-ins, failed log-in attempts, changes to the account

We collect some of this data also when you do not have an account or are not logged in; in that case it is necessary for the functioning and the security of the website.

2.3. Data from third-party sources

Source	Data
Mollie	Payment status, identification status, information on disputed transactions
Public registers: the Commercial Register, the National Tourist Register, registers of Member States	Registration and categorisation data, validity of registration numbers
Fraud prevention service providers	Transaction risk scores, alerts on matches with known risk profiles
Third-party single sign-on services (if you use such a log-in)	Name, email address, profile picture (only to the extent you have authorised)
Other users	Content of reports, complaints, reviews and Damage Reports that concern you

3. Why and on what basis we process the data

The table below fulfils the requirements of Article 13(1)(c) and Article 13(2)(a) GDPR: for each purpose the legal basis and the retention period are indicated.

3.1. Purposes, legal bases and retention periods

No.	Purpose	Categories of data	Legal basis (Article 6 GDPR)	Retention period
A	Creation and maintenance of an account	Account, profile	Article 6(1)(b) GDPR: performance of a contract	For as long as the account is active + 5 years after its closure (the general limitation period under Article 110 of the Bulgarian Obligations and Contracts Act (Zakon za zadalzheniyata i dogovorite))
A1	Recording of access and security logs	Log-in records, failed attempts, changes to the account, IP address	Article 6(1)(f) GDPR: legitimate interest in the security of accounts	12 months
B	Processing and performance of a Booking; communication between Guest and Host	Account, booking data, messages	Article 6(1)(b) GDPR: performance of a contract for the Guest; Article 6(1)(f) GDPR: legitimate interest in performing the Booking requested by the Guest, as regards the accompanying persons	5 years from the end of the stay
C	Acceptance of payments and Payouts	Payment data, transaction identifier	Article 6(1)(b) GDPR: performance of a contract; Article 6(1)(c) GDPR: for accounting purposes	Accounting registers and financial statements: 10 years, counted from 1 January of the following reporting period (Article 12(1)(2) of the Bulgarian Accountancy Act (Zakon za schetovodstvoto)); invoices and primary accounting documents: until expiry of the periods under Article 38 of the Bulgarian Tax and Social Insurance Procedure Code (Danachno-osiguritelen protsesualen kodeks) and Article 121 of the Bulgarian Value Added Tax Act (Zakon za danak varhu dobavenata stoynost)
D	Issuing and keeping accounting and tax documents	Identification and payment data	Article 6(1)(c) GDPR: legal obligation (the Accountancy Act, the Value Added Tax Act, the Tax and Social Insurance Procedure Code)	Accounting registers and financial statements: 10 years, counted from 1 January of the following reporting period (Article 12(1)(2) of the Accountancy Act); invoices and primary accounting documents: until expiry of the periods under Article 38 of the Tax and Social Insurance Procedure Code and Article 121 of the Value Added Tax Act
E	Verification of the identity of Hosts and of their Properties	Identity data, registration data, documents	Article 6(1)(c) GDPR: Article 30 of Regulation (EU) 2022/2065 and Regulation (EU) 2024/1028	6 months after termination of the contractual relationship, unless a law requires a longer period
F	Reporting of short-term accommodation activity data to the competent authorities	Registration number, address, URL, number of nights, number of guests, country of residence of the guests	Article 6(1)(c) GDPR: Article 9 of Regulation (EU) 2024/1028	As required by the Regulation; the receiving authorities retain the data for no more than 18 months
F1	Remembering the interface language you chose (cookie `OSTANY_LOCALE`, set when you choose a language, for example in the language switcher or in your account's language settings, or when you sign in with Google or Apple)	Language code	Article 6(1)(f) GDPR: legitimate interest in showing the site in the language you chose. Storing the cookie on your device is exempt from consent because it is necessary for the service you requested (Article 5(3) of Directive 2002/58/EC; Article 4a(4) of the Bulgarian E-Commerce Act)	1 year from the last time you chose a language or signed in
F2	Displaying maps: on a listing page and on the page of your trip, if you allowed it in the cookie banner, the interactive Google map, which loads by itself when the map section comes into view or close to it; otherwise, on a listing page, the picture of the map, which your browser loads directly from Google when the map section comes into view or close to it, and on both pages the interactive Google map only after you click the map picture, "Show map" or the map's full-screen button; in the map view in search and in the Hosts' tools for their own Listings, the interactive Google map when you open them; see the Cookie Policy, section 4	IP address, browser and device data, address of the Ostany website or page and, for the map picture, the location of the Property as shown in the Listing, sent by your browser directly to Google	Article 6(1)(a) GDPR: your consent, given in the cookie banner, for the interactive map that loads by itself on a listing page or on the page of your trip (Article 5(3) of Directive 2002/58/EC; Article 4a of the Bulgarian E-Commerce Act). You can withdraw it at any time through "Cookie settings" at the bottom of our pages, without affecting the lawfulness of processing before the withdrawal. Article 6(1)(f) GDPR: legitimate interest in showing you where Properties are, for the map picture; without your consent, the interactive map on a listing or trip page loads only at your request (your click)	We do not keep this data; Google keeps it under its own privacy policy (see section 1.3)
G	Due diligence and reporting to the National Revenue Agency under DAC7; notifying the Host of the information reported in respect of it. In accordance with Article 25(4) of Directive 2011/16/EU, we notify each Host who is a natural person individually and in sufficient time before the reporting, at least once a year, of the information that will be submitted in respect of that Host.	Name, address, TIN, VAT number, date of birth, address of the Property, quarterly amounts	Article 6(1)(c) GDPR: Directive (EU) 2021/514 and Section VIII of Chapter Sixteen of the Tax and Social Insurance Procedure Code	10 years, in accordance with the requirements for the retention of tax documentation
H	Customer support and handling of enquiries	Messages, account data, content of the communication	Article 6(1)(b) GDPR for enquiries relating to the contract; Article 6(1)(f) GDPR: legitimate interest in providing quality support	3 years from closure of the case
I	Prevention, detection and investigation of fraud and abuse; security of the Platform	Technical data, usage data, reports, risk scores	Article 6(1)(f) GDPR: legitimate interest in protecting the Platform, its users and third parties against fraud and abuse	3 years from the last recorded event; where fraud is established, 5 years
J	Content moderation and handling of reports and complaints	Content, reports, case file	Article 6(1)(c) GDPR: Regulation (EU) 2022/2065; Article 6(1)(f) GDPR: legitimate interest in maintaining a safe environment	2 years from closure of the case file
K	Resolution of disputes, including Damage Reports	Booking data, evidence, communication	Article 6(1)(f) GDPR: legitimate interests; Article 9(2)(f) GDPR where the claim contains health data	5 years from closure (Article 110 of the Obligations and Contracts Act)
L	Display and ranking of Listings in response to the search you make, without a personal profile (personalisation for signed-in users is purpose M)	Search criteria you enter, language	Article 6(1)(f) GDPR: legitimate interest in providing a relevant service	Not stored for this purpose; used only to show you the results
M	Personalised recommendations and personalised ordering of Listings for signed-in users, based on your own activity on the Platform. This is switched on by default; you can switch it off at any time in Account settings, under Privacy, using the "Personalised recommendations" switch. While it is switched off, we do not record the Listings you view or the searches you make for this purpose and we do not personalise what you see. Switching it off also deletes the stored record of the Listings you viewed and the searches you made; your saved Listings and Bookings are kept for their own purposes.	Listings you view while signed in (with the number and time of the views), searches you make while signed in (city, price range, number of guests, property type, amenities), Listings you have saved, your Bookings	Article 6(1)(f) GDPR: legitimate interest in showing you relevant Listings; you may object at any time (Article 21 GDPR), including by using the switch	Listing views: 365 days from the last view; searches: 180 days from the search; saved Listings and Bookings: as under purposes A and B
N	Direct marketing by email to our own customers	Email address, booking history	Article 6(1)(a) GDPR: consent (Article 6 of the Bulgarian E-Commerce Act (Zakon za elektronnata targoviya)) and Article 261 of the Bulgarian Electronic Communications Act (Zakon za elektronnite saobshteniya)	Until withdrawal of consent
O1	Server-side analytics and improvement of the services on pseudonymised data	Aggregated and pseudonymised usage data	Article 6(1)(f) GDPR: legitimate interest in developing the service	2 years, after which only in anonymised form
Q	Compliance with orders of competent authorities and defence of legal claims	All relevant data	Article 6(1)(c) GDPR: legal obligation; Article 6(1)(f) GDPR: legitimate interest in defending our rights	Until conclusion of the proceedings + the applicable limitation period
R	Protection of life and health in an emergency	Contact and location data	Article 6(1)(d) GDPR: vital interests	Until the necessity ceases to exist
S	Optional writing assistant for Hosts: preparing, at the request of the Host or of a person who manages the Listing on the Host's behalf, a draft of the description of a Listing from the details entered in the Listing (section 8.3(2)), and keeping a record of each draft	For the draft: the details entered in the Listing (type of property and of accommodation, town or village, neighbourhood and country, number of guests, bedrooms, beds and bathrooms, number of apartments, area, amenities, title, names of the photo sections, and the highlights and occasions chosen by the Host); never the address, the location on the map or the prices from the Listing, or the name or contact details from the Host's account. Text typed into the title, the neighbourhood or the names of the photo sections is sent as typed. For the record: the account that requested the draft and the Listing concerned, the language and length of the draft, the model and the version of the instructions used, the number of attempts, the date and time, and a cryptographic hash (SHA-256) of the text of the draft	Article 6(1)(b) GDPR: performance of a contract, for the draft requested by the Host; Article 6(1)(f) GDPR: legitimate interest in controlling the cost, quality and misuse of the writing assistant, for the record	We do not store the details sent to Google for this purpose; the draft is stored only if the Host saves it as the description of the Listing. The record, which contains neither the text of the draft nor the details sent: 2 years from the preparation of the draft, or until the Listing is erased if that is earlier; after the account is closed, it is no longer linked to the name or e-mail of the Host (see section 6(2a))

No processing for the tourist tax. We process no personal data for the purpose of collecting, declaring or remitting the tourist tax, of keeping the register of accommodated persons or of submitting data to ESTI (see section 1.3).

3.2. Data relating to persons who have not provided it to us themselves

(1) Where we process data of accompanying persons, the source of the data is the Guest who made the Booking. The categories of data are limited to the name and, where necessary for the accommodation, the age.

(2) In accordance with Article 14(5)(b) of Regulation (EU) 2016/679, providing the information directly to those persons would involve a disproportionate effort, since we do not hold their contact details. For that reason we publish this information and we task the Guest who provides the data with making them aware of it.

(3) Those persons have the same rights under section 7 and may exercise them at [privacy@domain].

3.3. Legitimate interests: specification

Where we rely on legitimate interests (Article 6(1)(f) GDPR), we have carried out and documented a balancing assessment in accordance with Guidelines 1/2024 of the European Data Protection Board. Our specific interests are:

Purpose F1: showing the site in the language you chose, without asking you again on every visit.
Purpose F2: showing you where a Property is. The picture of the map on a listing page contains only the location shown in the Listing (approximate, unless the Host has chosen to show the exact one), runs no Google code on our site and sets no cookie on it; your browser loads it directly from Google because Google's terms require that. Without your consent, the interactive map, which loads Google's code and fonts, is loaded on a listing page only when you click the map picture, or "Show map" where no picture is shown, and on the page of your trip only when you click "Show map"; on both pages it is also loaded when you click the map's full-screen button, first in full screen and then, once you close that view, in the map section of the page (after any of these clicks, also on other listing and trip pages you open in the same browser tab, until you reload the page or close the tab; see the Cookie Policy, section 4). If you allowed it in the cookie banner, the interactive map loads by itself and no picture is loaded; that processing is based on your consent (see section 3.1), not on this interest.
Purpose I: protection of the Platform, of our users and of third parties against fraud, account takeover, money laundering and abuse. Without this processing we would be unable to detect fraudulent Listings and compromised accounts.
Purpose J: maintaining a lawful and safe environment, which is also our obligation under the Digital Services Act.
Purpose K: the ability to resolve disputes between Guests and Hosts objectively, instead of leaving the parties to their own devices.
Purpose L: the delivery of relevant results; without processing search data the service would be practically unusable.
Purpose M: showing you Listings that are relevant to you. The processing is limited to what you do on Ostany while signed in, is not shared with third parties or used for advertising, does not produce legal or similarly significant effects, and can be switched off at any time in Account settings, under Privacy, using the "Personalised recommendations" switch.
Purpose O1: identifying problems and improving the service, using pseudonymised data.
Purpose S: keeping a record of the drafts prepared by the writing assistant, without their text, so that we can control its cost, detect misuse and check how drafts are used, including how often a draft is published without changes.

You have the right to object to any processing based on legitimate interests (see section 7).

3.4. Tax reporting under DAC7: special notice

(1) The Platform is a platform operator required to report information under Directive (EU) 2021/514 (DAC7) and Section VIII of Chapter Sixteen of the Bulgarian Tax and Social Insurance Procedure Code.

(2) If you are a Host, every year in January, before the report is filed, you will receive an individual notification by email containing a statement of the data that will be reported in respect of you: identification data, the address of each Property, the number of days let, the total consideration paid out per quarter, and the fees and commissions withheld. The same statement is available at any time in your account.

(3) The data is submitted to the National Revenue Agency by 31 January of the year following the reporting year. For Properties in other Member States, including the Hellenic Republic, the information is exchanged automatically between the National Revenue Agency and the relevant national tax authority.

(4) If you do not provide the data requested, then after two reminders and upon the expiry of 60 days the Platform is required by law to suspend Payouts to you and/or to close your account.

4. To whom we disclose the data

4.1. Categories of recipients

Recipient	What data	Why
The Host of the booked Property	Name, number of guests, dates, messages, telephone number upon a confirmed booking, special requirements you have communicated	Performance of the accommodation contract
The Guest, in the case of Hosts	Name, public profile, contact details upon a confirmed booking, address and access instructions	Performance of the accommodation contract
Mollie B.V. (the Netherlands)	Identification, payment and transaction data; for Hosts, the full KYC package	Payment processing, obligations under AML legislation
Hosting and cloud infrastructure provider: [name, country]	All data stored on the Platform	Technical operation
Email and notification service provider: [name, country]	Name, email address, content of the notification	Sending transactional and marketing messages
Google Ireland Limited (Ireland) / Google LLC (USA), when your browser loads the map picture on a listing page or an interactive Google map	IP address, browser and device data, address of the Ostany page (for the map picture, of the Ostany website), sent directly by your browser; for the map picture, also the location of the Property as shown in the Listing	Displaying maps (Article 6(1)(f) GDPR: legitimate interest in showing you where Properties are; the interactive map on request or, where it loads by itself on a listing or trip page, Article 6(1)(a) GDPR: your consent); Google acts as an independent controller for its own purposes (see section 1.3)
Fraud prevention service provider: [name, country]	Technical data, transaction data	Risk assessment
Sign in with Google / Apple: Google Ireland Limited / Google LLC and Apple, only if you choose to sign in with them	Your sign-in request; in return they send us your name and email address and, for Google, your profile picture	Signing you in to your account (purpose A); each acts as an independent controller for its own processing
Identity verification provider: Didit [legal entity, country]	Identity document image, document data, selfie	Identity verification (purpose E)
File storage provider: UploadThing [legal entity, country]	Photos and files you upload	Storage and delivery of images (processor)
Automated content moderation providers: OpenAI [legal entity, country] and Google Cloud Vision (Google Ireland Limited / Google LLC)	Photos, names, descriptions and reviews you submit	Content moderation (purpose J)
Artificial intelligence service provider: Google (Gemini API), Google LLC (USA)	The content of Listings (texts and photos) and, when a Listing is moderated, the profile description of its Host; the reviews you submit and the name you enter in your profile; for the import of a Listing, the content of the Host's listing page on another platform, the link to which the Host provides; for the writing assistant, only the details of the Listing set out under purpose S	Automated content moderation (purpose J); automatic translation of Listings and reviews; at the request of the Host, the import of a Listing, suggestions of the occasions for which a Listing is suited and drafts of the description of a Listing (purpose S); see section 8.3. Google acts as our processor. Under the terms on which we use the service, Google does not use the data to improve its products and retains it only for a limited period, to detect abuse and to meet legal obligations
Competent authorities under Regulation (EU) 2024/1028: for the Republic of Bulgaria, the Ministry of Tourism and/or the single digital entry point; for the Hellenic Republic, the competent authority and the Greek single digital entry point; for other Member States, the relevant national authority	Registration number, address, URL of the Listing, number of nights, number of guests, country of residence	Legal obligation
Ανεξάρτητη Αρχή Δημοσίων Εσόδων (Α.Α.Δ.Ε., the Greek Independent Authority for Public Revenue), Hellenic Republic	Data identifying Hosts of Greek Properties, upon request	Legal obligation: Article 111(7) of Greek Law 4446/2016; and automatic exchange under DAC7 through the National Revenue Agency
National Revenue Agency	Host data under DAC7	Legal obligation
Law enforcement authorities, courts, supervisory authorities	The relevant data	Legal obligation or defence of rights
The other party to a dispute	Data from the dispute case file	So that it can submit its position and evidence; legitimate interest in an adversarial and objective examination of the dispute
External legal, accounting and audit advisers	The relevant data	Legitimate interest in professional advice and defence
An acquirer in the event of a corporate reorganisation or a transfer of the business	All data	Legitimate interests; we will notify you in advance

4.2. Publicly visible information

The following are publicly visible on the Platform: your name (or part of it), your profile picture, your profile description, the reviews you have given and received, and the location of the Property: its approximate location or, if the Host has chosen to show it, its exact location on the map (the exact address is disclosed only after a confirmed booking).

Publicly visible information may be indexed by search engines. Reviews and other content you have shared may remain visible after the closure of your account, except where you request their erasure and there is no ground for retention.

4.3. Processors

We have concluded agreements under Article 28 GDPR with all providers that process personal data on our behalf, obliging them to process the data only on our instructions, to guarantee an appropriate level of security and not to engage sub-processors without our authorisation.

4.4. What we do not do

We do not sell personal data. We do not use the content of your messages for advertising purposes.

5. International transfers

(1) As a matter of principle we process data within the territory of the European Economic Area. Mollie B.V. is established in the Netherlands; no transfer outside the EEA takes place. When your browser loads the map picture on a listing page or an interactive Google map, it sends data directly to Google, which may process it in the USA; Google LLC is certified under the EU-US Data Privacy Framework, for which the European Commission adopted an adequacy decision (Implementing Decision (EU) 2023/1795). Some of our processors (file storage, automated content moderation and the artificial intelligence services described in section 8.3) may process data in the USA; see paragraphs (1a) and (2).

(1a) Google LLC, which provides the Gemini API that we use for the purposes listed for Google (Gemini API) in the table in section 4.1, processes the data we send to it in the USA and may store it temporarily in other countries where Google or its subprocessors have facilities. The transfer to Google LLC in the USA is based on the adequacy decision referred to in paragraph (1), as Google LLC is certified under the EU-US Data Privacy Framework; a transfer to any other country outside the European Economic Area is based on the Standard Contractual Clauses incorporated in Google's data processing terms (paragraph (2)). Google processes the data as our processor under those terms.

(2) Where an individual provider processes data outside the European Economic Area, we apply an appropriate mechanism under Chapter V of Regulation (EU) 2016/679: an adequacy decision or Standard Contractual Clauses under Commission Implementing Decision (EU) 2021/914, accompanied by a transfer impact assessment and by supplementary technical measures, including encryption in transit and at rest and pseudonymisation. An up-to-date list of such providers and of the mechanisms applied is made available on request at [privacy@domain].

(3) We do not rely on the derogations under Article 49 GDPR as a general basis for systematic transfers. The derogations are applied only to occasional transfers, in accordance with EDPB Guidelines 2/2018.

(4) You have the right to obtain a copy of the safeguards applied; write to [privacy@domain].

6. Retention periods

(1) The specific periods are set out in the table in section 3.

(2) The general principles we apply are:

Ground for retention	Period
Payroll records	50 years (Article 12(1)(1) of the Accountancy Act)
Accounting registers and financial statements	10 years, counted from 1 January of the reporting period following the one to which they relate (Article 12(1)(2) of the Accountancy Act)
Invoices and other primary accounting documents	Until expiry of the periods under Article 38 of the Tax and Social Insurance Procedure Code and Article 121 of the Value Added Tax Act
Tax documentation and DAC7	10 years and until expiry of the limitation periods under the Tax and Social Insurance Procedure Code
Contractual relationships and potential claims	5 years, the general limitation period under Article 110 of the Obligations and Contracts Act
Traceability data on Business Hosts	6 months after termination of the relationship (Article 30 of Regulation (EU) 2022/2065)
Security logs	12 months
Records of communications with customer support	3 years; call recordings: 30 days
Record of the withdrawal of marketing consent	5 years
Reports under Regulation (EU) 2024/1028	24 months from transmission, in order to demonstrate compliance
Tax and accounting documentation for Properties in the Hellenic Republic	10 years
Records of the drafts prepared by the writing assistant (purpose S), which do not contain the text of the draft	2 years from the preparation of the draft, or until the Listing is erased if that is earlier
Data processed on the basis of consent	Until withdrawal of consent

(2a) Closing your account. When you delete your account we erase your profile (name, photo, description, contact details, log-in data, saved payment cards, payout bank details, identity-verification data, messages, device history, saved places, notifications and preferences). Bookings, payments and the related accounting records are retained for the periods above in pseudonymised form (no longer linked to your name or e-mail) because we are legally obliged to keep them, and may be used in that form for statistical and research purposes (Article 89 GDPR). Reviews remain visible under "Former guest". A Host's Listings are deactivated and kept without the street address and exact location. You cannot delete your account while you have a current or future booking (as Guest or Host) or earnings not yet paid out; complete or cancel them first.

(3) Upon expiry of the period the data is erased or irreversibly anonymised. Back-ups are overwritten according to an established schedule and are erased no later than 90 days after erasure in the production environment.

(4) Where a dispute, proceedings or investigation is pending, we retain the relevant data until its final conclusion, irrespective of the periods indicated above.

7. Your rights

Under Regulation (EU) 2016/679 you have the following rights:

Right	Article	What it means
Access	Article 15	To obtain confirmation as to whether we process your data, a copy of it and information about the processing
Rectification	Article 16	To request the correction of inaccurate data and the completion of incomplete data
Erasure ("right to be forgotten")	Article 17	To request erasure where the data is no longer necessary, you have withdrawn your consent, you have objected on justified grounds, or the processing is unlawful
Restriction of processing	Article 18	To request the temporary suspension of the processing while the accuracy of the data or the merits of an objection are verified
Data portability	Article 20	To receive the data you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another controller
Objection	Article 21	To object to processing based on legitimate interests. You may object to direct marketing at any time and the processing is then discontinued unconditionally.
Withdrawal of consent	Article 7(3)	To withdraw a consent given at any time, without this affecting the lawfulness of processing carried out before the withdrawal
Human intervention in automated decision-making	Article 22(3)	See section 8
Complaint to a supervisory authority	Article 77	See section 12

7.1. How to exercise your rights

(1) Through Account settings, to view and correct your account data and to switch off personalised recommendations. Through "Cookie settings" at the bottom of our pages, to give or withdraw your consent for the interactive Google map loading by itself on listing and trip pages.

(2) By a written request to [privacy@domain] or to the address [postal address].

(3) In order to protect your data, we may request additional information to confirm your identity. We do not request more data than is necessary for identification.

(4) We respond within one month of receipt of the request. Where the request is complex or where a large number of requests is received, that period may be extended by a further two months, and we will inform you of the extension and of the reasons for it within the first month.

(5) The exercise of your rights is free of charge. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee or refuse to act, giving reasons for the refusal.

(6) If we refuse to comply with a request, we state the grounds and inform you of your right to lodge a complaint with the CPDP and of your right to an effective judicial remedy.

8. Automated decision-making and profiling

8.1. Profiling without legal effects

We use profiling for: personalised recommendations and the personalised ordering of Listings for signed-in users (purpose M), which you can switch off in Account settings, under Privacy, using the "Personalised recommendations" switch; and fraud risk scoring (purpose I). These processes do not in themselves produce legal effects concerning you.

8.2. Automated decisions with legal or similarly significant effects

(1) In limited cases automated systems may restrict or suspend your access to the Platform, block a transaction or decline a booking where they detect conduct indicating fraud, a compromised account or a safety risk.

(2) Logic involved: the system analyses a combination of signals: the correspondence between the payment data and the account data, the speed and sequence of actions, matches with known fraud patterns, account history, technical characteristics of the device and the connection, and alerts from our fraud prevention provider. Each signal carries a weight and, where a defined threshold is exceeded, a measure is triggered.

(3) Significance and envisaged consequences: the possible consequences are the refusal of a specific transaction, the temporary restriction of access to certain functionalities, the suspension of the account or a refusal to publish a Listing. These measures may prevent you from completing a booking or, in the case of Hosts, from receiving a Payout.

(4) Your rights under Article 22(3) GDPR. You have the right to:

request human intervention on our part;
express your point of view and provide additional information;
contest the decision.

You exercise these rights via [privacy@domain] or through the internal complaint-handling system at [link]. We examine the request without automated means and issue a reasoned decision within 14 days.

(5) Automated decisions are not based on special categories of personal data within the meaning of Article 9 GDPR.

8.3. Artificial intelligence

(1) We use artificial intelligence systems for the ranking and recommendation of Listings, for the automated detection of fraud and abuse, for the automated moderation of content (purpose J) and for the automatic translation of Listings and reviews into the language in which you use the Platform. At the request of a Host, we also use them to import a Listing from another platform, to suggest the occasions for which a Listing is suited and to draft the description of a Listing (paragraph 2).

(2) The Platform does not provide an automated assistant (chatbot). Hosts may use an optional writing assistant which, at the request of the Host or of a person who manages the Listing on the Host's behalf, drafts the description of a Listing from the details entered in the Listing (purpose S). A draft is never published automatically: the Host must review it and correct it where necessary before saving it, decides whether to save it, and is responsible for the description it publishes, as for any other content of its Listing. Descriptions prepared with the writing assistant therefore carry no separate visible label for Guests. Automatic translations of Listings and reviews are labelled as such, and you can display the original text at any time. If an automated assistant is ever introduced, you will be informed before the beginning of any conversation with it and will be able to request to be transferred to a human.

(3) We do not use your personal data to develop or train artificial intelligence models. If that ever changes, we will ask for your consent first.

9. Security

(1) We implement appropriate technical and organisational measures under Article 32 GDPR, including: encryption in transit (TLS) and encryption of sensitive data at rest; hashing of passwords; access control on a need-to-know basis; multi-factor authentication for administrative access; logging of access to personal data; regular back-ups; vulnerability and patch management; and staff training.

(2) We do not store full payment card data. It is processed directly by Mollie in accordance with the PCI DSS standard.

(3) In the event of a personal data breach resulting in a high risk to your rights and freedoms, we will notify you without undue delay and will notify the CPDP within 72 hours of becoming aware of it, in accordance with Articles 33 and 34 GDPR.

10. Children's data

(1) The Platform is not intended for persons under 18 years of age and we do not knowingly collect the data of such persons for registration purposes.

(2) Data concerning minors may be processed only as part of a booking made by an adult, and then only to a minimal extent (name and age, where necessary for the accommodation).

(3) If we establish that we have registered an account of a person under 18 years of age in breach of paragraph 1, we close the account and erase the data. This does not affect the processing under paragraph 2. If you believe that we hold such data, write to [privacy@domain].

11. Cookies and similar technologies

(1) The use of cookies, local storage, pixels and similar technologies is governed by the separate Cookie Policy: /legal/cookies-policy.

(2) Apart from the one optional purpose described below, we use only cookies and similar technologies that are strictly necessary for the service you explicitly requested, including a cookie that stores the language you chose and a cookie that stores your cookie choice. These are exempt from prior consent under Article 5(3) of Directive 2002/58/EC as amended by Directive 2009/136/EC and Article 4a(4) of the Bulgarian E-Commerce Act. We do not use analytics or advertising cookies, pixels or similar technologies. The one optional purpose is letting the interactive Google map load by itself on listing pages and on the pages of your trips (purpose F2). We ask for your consent for it in a banner on your first visit, with equally prominent options to accept ("Allow") and to refuse ("Only necessary"); you can withdraw it at any time, as easily as you gave it, through "Cookie settings" at the bottom of our pages (see the Cookie Policy, sections 2 and 4).

(3) If we ever want to use any other technology that is not strictly necessary, we will first update this Policy and the Cookie Policy and ask for your prior consent (opt-in) within the meaning of Article 4(11) and Article 6(1)(a) of Regulation (EU) 2016/679, before the technology is used. Consent will be asked granularly, per purpose, through equally prominent options to accept and to refuse, and you will be able to withdraw it at any time as easily as you gave it.

12. Right to lodge a complaint

(1) If you consider that the processing of your personal data infringes the law, you have the right to lodge a complaint with:

the Bulgarian Commission for Personal Data Protection (CPDP)

Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Telephone: 02/915 3518

Email: kzld@cpdp.bg

Website: www.cpdp.bg

If your habitual residence is in the Hellenic Republic, or the infringement relates to a Property located there, you may also lodge a complaint with:

Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (the Hellenic Data Protection Authority)

Κηφισίας 1-3, 115 23 Αθήνα, Ελλάδα (Kifisias 1-3, 115 23 Athens, Greece)

Telephone: +30 210 6475600

Email: contact@dpa.gr

Website: www.dpa.gr

(2) You also have the right to lodge a complaint with the supervisory authority of your habitual residence or of the place of the alleged infringement.

(3) You also have the right to an effective judicial remedy against a decision of a supervisory authority and against a controller or processor (Articles 78 and 79 GDPR).

(4) Before doing so, we would be glad to look into the matter; write to us at [privacy@domain].

13. Amendments to the Policy

(1) We may amend this Policy. The current version is always available at [link], with the date indicated.

(2) In the event of material amendments (affecting the purposes, the legal bases, the categories of recipients or the retention periods), we will notify you by email at least 30 days before they enter into force.

(3) Where an amendment requires new consent, we will request it from you explicitly. Without consent, processing on the relevant basis does not take place.

(4) Archive of previous versions: [link].

Credits: place names. The city names in the search and in the hosts' address form are adapted from GeoNames (geonames.org), licensed under the Creative Commons Attribution 4.0 International licence (CC BY 4.0). We selected, corrected and converted some of these names (for example into the Latin alphabet for Serbian). GeoNames does not endorse Ostany.