Cookie policy

01What cookies are

Cookies are small text files a site leaves in your browser so it can remember something about your visit — which language you chose, what you decided about cookies themselves, how far you got in a booking. Some disappear when you close the browser; others stay for a set time. Alongside cookies, some systems also use the browser's local storage (localStorage and sessionStorage), which works in much the same way — everything written here applies to it too.

02The legal basis

The Bulgarian Electronic Communications Act (Article 4a) and the General Data Protection Regulation divide cookies into two groups.

• Necessary cookies need no consent: without them we cannot show you the site in your language, remember your decision or take the booking you have asked for. We use them because the service requires them (Article 4a(2) of the Electronic Communications Act) and on the basis of our legitimate interest in a site that works securely and correctly (Article 6(1)(f) GDPR).
• The site's own analytics and marketing cookies are set only after your explicit consent (Article 4a(1) of the Electronic Communications Act and Article 6(1)(a) GDPR). The booking engine is the exception: it loads without consent, because without it the service you came for does not exist.
• You can withdraw consent at any time, as easily as you gave it — under "Change your cookie choice" at the foot of every page, which deletes the stored consent. Withdrawing it does not affect what was processed before.

03Which cookies we use

• Necessary: the bi_consent cookie, which keeps your cookie choice; NEXT_LOCALE, which remembers the language if you switched it; and the Exely booking engine's own session cookies, without which the booking form cannot work.
• Analytics: Google Analytics, which Exely loads according to our hotel profile's settings, and Exely's own statistics on how the form is used. They show us how guests search for and book rooms. They run only with your consent.
• Marketing: none at present. The site loads no advertising pixels and shares no data with advertising platforms. Should that change, we will update this policy and ask you before switching them on.

04The Exely booking engine

Bookings on this site go through Exely, an external online booking system the complex works with. The form on the home page and on the "Book your stay" page is loaded from Exely's servers (bg-ibe.hopenapi.com).

• Exely sets its own cookies and browser records on our site: for instance TLV_bg or TLV_en, which for 30 days remembers when and from where you reached the booking form, as well as technical identifiers for the form's session. The form itself runs in a frame on an Exely address and keeps cookies there that the booking steps and abuse protection need — their exact names and lifetimes are set by Exely.
• According to our hotel profile's settings, Exely also loads Google Analytics (the _ga and _ga_0XTP7T1LY3 cookies), which shows us how the form is used. It comes with the form and is not ours to switch off — your browser's settings can restrict it.
• Exely's script also contains modules for advertising platforms, but none of them is enabled in our profile. If we ever enable one, it will be reflected here.
• For the data it processes as a system in its own right, Exely answers under its own rules — the "Exely privacy policy" and "Exely cookies policy" published on exely.com.

05How to change or withdraw your choice

• Press “Change your cookie choice” at the foot of any page (or the button below): the stored consent is deleted and the notice appears again. If you do not agree again, the site's analytics cookies do not load.
• Your choice is kept for 180 days in the bi_consent cookie. After that we will ask you again. We will also ask sooner if the policy changes in a way that calls for it.
• You can also delete or block cookies in your browser's settings. Bear in mind that deleting bi_consent brings the choice window back, and blocking all cookies may stop the booking form from working.

06If you decline the optional cookies

The site works as usual — every page, photo and piece of information is available, and the booking form loads, because it is the service you asked for. Only the site's analytics cookies stay off. And you can always book by telephone.

07Your rights

Insofar as cookies contain personal data (for example an identifier that tells your browser apart), you have every right under the General Data Protection Regulation:

• to ask for access to the data we hold about you, to have it corrected or erased;
• to restrict processing, to object to it or to withdraw your consent;
• to lodge a complaint with the Bulgarian Commission for Personal Data Protection (Комисия за защита на личните данни) — 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, www.cpdp.bg, kzld@cpdp.bg.
• To exercise your rights, write to bozheime@gmail.com. We reply within a month.

08Changes to this policy

When we add or remove cookies, we will update this text and the date at its top. For a substantial change — a new category of cookies, say — we will ask for your consent afresh.