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Privacy policy


This Personal data security and protection policy (“Security Policy”) applies to the Five Elements Hotel. The Five Elements Hotel (hereinafter referred to as “us”) undertakes the responsibility to protect your personal data and we would like to inform you of what categories of data the Five Elements Hotel collects and processes for you, for what purpose, on what grounds, for what period, to which persons we could transfer them and how we keep them.

Please note that by using this website or its mobile version, you agree to all actions taken by us with respect to your personal information as described in this Security Policy. If you do not agree with the terms of this Policy, please do not use the Site or provide personal information to the Five Elements Hotel through our Site or otherwise.


We, at the Five Elements Hotel, strive to provide our customers with exceptional products, services and a top-class experience. We give high priority to our business, but we always put Loyalty and respect for our customers above it. We are fully aware of the importance of privacy and the protection of everyone’s privacy. That is why we have prepared this Personal data security and protection policy at the Five Elements Hotel to make our procedures for processing personal data that we collect from you or about you in our hotel, on this site or through our applications, through written or oral communication with us when you visit any of our sites or from other sources, public and transparent.

Please note that this Security Policy does not apply to the way we process personal data on behalf of or as directed by third parties, such as travel agents, airlines, car rental companies and other service providers, companies that organize or offer package travel services, marketing partners or corporate clients.



„Personal data“ means:
– any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

– or in short – personal data, this is any information or data that is related to you or may “lead” to you. For example – personal data is without a doubt your full name in combination with your PIN. But personal data is also, for example, the data from the payment instruments you use, which in combination with additional information – places where you paid, can reveal many things about you. Here’s how, without explicitly stating your name or photo, the “traces” that your data leaves can reveal your interests, your property, your routes, etc.
We at the Five Elements Hotel are well aware of the challenges facing the protection of the personal space of our clients and we try to protect it to the maximum extent.

By using our website, registering at and visiting our hotel, and / or using any of our products or services, you consent to the collection and processing of your personal data as described in this Security Policy.


Hotel Five Elements is owned by Rila Megatour OOD, UIC: 200010555, which is the data administrator for all guests.

Changes to the Data security and protection Policy of the Five Elements Hotel


These are the six principles of the Five Elements Hotel that guide us when we process your personal data:

  1. Transparency: When the Five Elements Hotel collects and processes your personal data, we provide you with all information about how and from what sources we collect your data, for what purpose we collect it, for how long we store it, to whom we would potentially transfer it, who are the potential recipients of your data, what are your rights as a data subject.
  2. Proportionality: We at the Five Elements Hotel collect only the minimum necessary personal data, as much as necessary to effectively operate.
  3. Accuracy and up-to-dateness: We at the Five Elements Hotel process only up-to-date and accurate data. We take all measures to ensure that the personal data we store is accurate and up-to-date.
  4. Time limit: We at the Five Elements Hotel store your personal data only for the period necessary for the effective exercise of our activity and in accordance with the provisions of the law.
  5. Observance of the rights of the data subjects – We at the Five Elements Hotel guarantee the observance of your rights to access, rectification, erasure of your personal data that we process.
  6. Confidentiality and security: We at the Five Elements Hotel have provided all necessary administrative, technical and organizational measures to protect your personal data against unwanted changes, accidental or illegal losses or unauthorized use, disclosure or access.



At any point of contact or interaction (reservation, registration, visit, etc.) with you – our guests, as well as in carrying out various aspects of our activities, we can collect your personal data, which you personally provide to us. These categories of personal data are:

Contact information – contact information for you, your names, postal address, e-mail address and telephone number;

Identification information – data from your identity document, in case you are our guest

Sensitive personal data – this is data revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying an individual, health data or data on the sexual life or sexual orientation of the individual. We at the Five Elements Hotel generally do not collect sensitive information unless it is provided voluntarily by you or unless we are required to do so under applicable laws or regulations. We may use the health information you provide to better serve and meet your specific needs (for example, to provide access for people with disabilities)..

Personal data of children

We at the Five Elements Hotel do not collect and process personal data of and concerning persons under 18 years of age. As a parent or legal guardian, do not allow your children to send personal information without your permission.

Payment information – data from your payment service provider, credit card number or other payment account number, account data related to mobile payments; billing address and other payment information needed to make, prove, and account for your payment.

Data related to your reservation, stay or visit – information about your stay, date of arrival and departure, purchased goods and services; data collected through the use of CCTV systems, your key card and other security systems.

Data related to your personal preferences and interests expressed during your stay (e.g. smoking or non-smoking room, preferred floor, type of bedding, type of newspapers / magazines, sports, cultural interests). Your questions / comments during or after your stay at our hotel or any of its facilities.

Communication and correspondence – Information related to the provision of the service – records and copies of your correspondence, if you contact us; as well as any kind of communication between you and employees of the Five Elements Hotel.

Event Participation Information – Data related to your participation in an event held in PBR – conferences, trainings, seminars, and other events: In case you participate in an event held on the territory of PBR, we collect details about the event, the date of the event, the number of guests, details about the guest rooms, and for corporate events – information about your company or organization. We also collect the data of the participants – in these cases we can share your personal data with the organizers of the event.

Loyalty program – Data related to our membership program or loyalty program, participation in a competition, lottery or marketing program, information related to the purchase and receipt of products or services from some of our establishments in the hotel building;

Marketing Data – Data related to our surveys – we may sometimes ask you to participate in our customer survey. Participation is always voluntary and just an opportunity. We may invite you to participate in our competitions, raffles and other events, information about which you can share with your contacts on social networks for evaluation by voting, shared offers or other promotions. Participation in such promotions is always an opportunity of your choice, not mandatory.

Video information – For your security, we use a surveillance system – video cameras located at various points in the hotel building. All security cameras are marked with information boards in visible places. The cameras can take or record photos of guests and visitors in public places, as well as information related to your location during your stay at our sites. PBR does not use a security and covert surveillance system. We do not perform covert video recording.

Your IP address

When you use the website of the Five Elements Hotel, we process your IP address data. An IP address is a set of numbers that is always assigned to your computer when you connect to your ISP or through your LAN / WAN network. Network servers automatically identify your computer by the IP address assigned by it during your online session.

The Five Elements Hotel may collect the IP addresses of users on its website for the purposes of system administration and verification of the use of our Internet addresses. We may also use IP addresses to identify users of our sites when we feel the need to enforce the terms of use of the sites or to protect our service, websites or other users.

In addition to the information we collect directly from you, we may also receive information about you from third parties.


In a number of cases we receive your personal data from third parties. These are:
Our partners providing online booking services such as:, and others.

Social networks – If you check in at the place of stay – our hotel – on social networks, if you choose to participate in activities or offers from PBR on social networks, we may receive certain information from your social network account according to your settings in the social network service, such as location, registrations, activities, interests, photos, status update, and friends list.



Legality of processing

The Five Elements hotel processes your identification information in accordance with the requirements of the Civil Registration Act – Article 99.

PBR processes your personal data, related to your payment, as necessary to comply with the requirements of tax, financial or other domestic law.

The other categories of data listed in this Data Protection Policy are processed by the Five Elements Hotel within the framework of the performance of the contract for provision of services with its clients.

The Five Elements Hotel processes your personal data for the following purposes:

The Five Elements Hotel processes your personal data for the purposes of accurate and conscientious performance of its contractual obligations to its customers, including the provision and personalization of services that customers request and expect from us.

The Five Elements Hotel processes your personal data related to the payment for our services in order to ensure the correctness and accuracy of the payment

The Five Elements Hotel processes your personal data for the purposes of clear and accurate communication with you about your reservation and stay with us.

The Five Elements Hotel processes your personal data recorded on our security cameras in order to ensure the protection of public order and security in the hotel and its establishments.

The Five Elements Hotel processes your personal data for the purposes of our customer satisfaction surveys and our loyalty programs.

The Five Elements Hotel processes your personal data for the purposes of the requirements of tax and accounting legislation – so that we can declare and report our income.



Employees of the Five Elements Hotel who have access to your personal data:

We at the Five Elements Hotel guarantee that our employees have access only to the personal data that is directly related to their work. In order to offer you the best service, we provide the following authorized employees with the minimum necessary access to your data:

Reservation staff.

IT staff.

Medical staff, where necessary.

Legal staff, if necessary.

Our partners:

– payment service providers – banks, non-cash payment systems, payment instruments such as PayPal, etc. Your personal data will be provided to the payment service provider you have chosen to make payment to us.

– organizers of group events and meetings: in case you visit the Five Elements Hotel as part of a group event or meeting, the information gathered regarding the planning of the meeting and the event will be shared with the organizers of these meetings and events and, where necessary, with guests, who organize or participate in the meeting or event.

– the accounting service providers that process our accounting

– state bodies and local self-government bodies

– In order to fulfill the requirements of the Civil Registration Act Art. 99, the Five Elements Hotel provides your identification data, as well as the data for your stay to the local self-government bodies, and upon request – to the Ministry of Interior.
– In order to meet the requirements of domestic legislation, the Five Elements Hotel provides information to the NRA.



The Five Elements Hotel stores your personal data for the period necessary to achieve the objectives described in this Security Policy, or as required by Bulgarian law.

The Five Elements Hotel stores your personal data recorded on our security cameras for the legally permissible period.

The Five Elements Hotel keeps your personal information collected in order to make guest reservations for the specified period after the stay.

We will destroy your personal data as soon as possible and in such a way that it cannot be reproduced or recovered.

The Five Elements Hotel guarantees that if your data exists printed on paper, it will be destroyed in a secure manner, for example by machine cutting into small pieces or burning of paper documents or otherwise, and if in electronic form, personal data will be destroyed by technical means so that they cannot be reproduced or restored.

The Five Elements Hotel guarantees that in case of collection of personal data for the purposes of specific campaigns, lotteries and any other promotions, the processing period will be specified in each case, and participants will be informed about it.



At any time, you have the right:

Request access to your personal data that the Five Elements Hotel processes, as well as receive a copy thereof.

To request the deletion of your personal data (the right to be forgotten) if you believe that the processing is no longer necessary for the purposes for which it was collected. Please note that this right cannot be exercised if a special law explicitly provides for the retention of this data for a certain period.

To request the correction of inaccurate personal data in cases where it does not correspond to the truth.

How to request access to your data?

We at the Five Elements Hotel understand that you would like to be informed of regarding the personal information we have about you. We will be happy to help you with your request for access to your personal data. However, in order to protect your personal information, at the time of your request we will have to ascertain that you are the subject of the requested data. When you make a personal request, we will ask you to provide some form of photo identification, such as a passport or driver’s license, and you will be asked to sign an application form.

When you submit a request for access to personal data, not on the spot with us, but through other means, we require the request to be made in writing by email, fax or letter, including a copy of an identity document and signature. We also need home and business addresses and phone numbers so that we can cross-reference them with our files and verify your identity.

The above procedure is necessary to create an audit trail on the way the request is processed. When a request is made, any correspondence or application is stored and added to your personal information.

The Five Elements Hotel reserves the right to refuse access to your personal information in certain circumstances. If your personal information is not disclosed to you, you will be informed of the reasons for refusing to grant you access to your personal data.

At any time, if you fear that your data protection rights have been violated, you have the right to lodge a complaint with the competent data protection supervisory authority – the Data Protection Commission –



The Five Elements Hotel take reasonable steps to:

(a) protect personal information against unauthorized access, disclosure, alteration or destruction; and (b) maintain personal information as accurate and up-to-date as appropriate.

The Five Elements Hotel uses an expert internal team of IT specialists who are responsible for creating, updating and managing the security program of the Five Elements Hotel.

In the event of a security incident, the Five Elements Hotel will notify regulatory authorities and / or consumers as required by applicable laws or regulations.

For online transactions, we use technological means within reasonable to protect the personal data you send us through our site. Please note that, unfortunately, there is no Internet-based security system or data transfer system that is guaranteed to be completely secure.

To protect your privacy, please do not email us payment card numbers or other confidential personal information.



If you have provided us with contact information (postal address, fax number, email address or telephone number), we may wish to notify you, depending on your preferences of our products and services, or invite you to participate in events through and via email, online advertising, social networks, telephone, text message (including SMS and MMS), targeted notifications, in-app notifications, mail, our customer service call center and other means (including on-site messaging such as TV in your room).

If you prefer that we do not send you marketing materials by email, you can unsubscribe at any time using the unsubscribe feature in the email you receive from us. Execution of unsubscribe requests may take up to ten business days.

To unsubscribe from text messages, inform the hotel reception that you do not wish to receive text messages from the hotel, or reply with “STOP” to the received message.

To be added to the internal no-call list of the Five Elements Hotel, send a message to:



We may change this Security Policy sporadically. When we make significant changes to this Security Policy, we will post a link to the updated Security Policy on the homepage of our site and if you have registered for any of your products or services, we may also notify you through the communication channel, provided by you. You will find out when this Security Policy was updated by checking the link and the date at the beginning of the Security Policy. All changes to our Security Policy will take effect upon publication of the amended Security Policy on the Site. By using the site and / or any of our products and services and / or accepting the updated Security Policy after such changes, you accept the Security Policy, as currently amended.



If you have any questions about this Security Policy or the way the Five Elements Hotel processes your personal data, or if you wish to send us with a compliment or complaint, you can contact us by email at We will respond within 30 days or sooner if applicable.

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