Privacy Policy

1. Controller of the personal data

The controller of the personal data collected through the website and through the free pilot request form is:

Web Trade EOOD is the developer and provider of the SayFIXED platform.

For the personal data contained in reports submitted through SayFIXED to a particular hotel, the controller is that hotel. In such cases Web Trade EOOD processes the data on behalf of and in accordance with the instructions of the hotel, acting as a processor.

2. What data we collect through the website

When you send a free pilot request, we process the following data:

• the name of the hotel or property;
• the name of a contact person;
• a work email address;
• an approximate number of rooms;
• city and country, if you choose to provide them;
• a phone number, if you choose to provide it;
• the content of the message, if you add one.

Where available, data about the source of the visit may also be added to the request, for example the referring page, the landing page of the visit and advertising campaign parameters.

If you have given consent to measurement or advertising, technical data about the visit may also be processed, including online identifiers, IP address, browser and device type, pages visited and interactions with the website.

3. What we use the data for

The data from the form is used for:

• reviewing and responding to the request;
• organising the free pilot;
• preparing the property, the rooms and the QR codes;
• conducting the necessary preliminary communication;
• preparing an offer and taking steps towards the possible conclusion of a contract;
• protecting the website and preventing abuse;
• measuring traffic and the effectiveness of the advertising, where the relevant consent has been given.

Sending a pilot request does not lead to the automatic conclusion of a contract, to the creation of a payment obligation or to an automatic transition to a paid subscription.

4. Legal bases

We process personal data on the following bases:

• in order to take steps at your request prior to the possible conclusion of a contract;
• for the purposes of our legitimate interest in conducting requested commercial communication, responding to enquiries and protecting the website against abuse;
• on the basis of your consent — where optional measurement and advertising technologies are used;
• for compliance with legal obligations, where such obligations are applicable.

You may withdraw your consent at any time via the “Cookie settings” link. The withdrawal takes effect for the future and does not affect the lawfulness of the processing carried out before it.

5. Use of Google and Meta

Only after explicit consent has been given may the website use:

• Google tag, Google Analytics or Google Ads, provided by Google Ireland Limited;
• Meta Pixel, provided by Meta Platforms Ireland Limited.

Once consent has been given, these providers may receive technical data and online identifiers, including IP address, browser and device information, the pages visited, the source of the visit and the actions taken on the website.

The relevant technologies are blocked by default and must not be loaded before consent has been given.

More information about the processing carried out by these providers can be found in:

• Google’s Privacy Policy;
• Meta’s Privacy Policy.

These providers may process data outside the European Economic Area, subject to the safeguards provided for in the legislation, including adequacy decisions and standard contractual clauses.

6. Who we disclose the data to

The personal data may be accessed by:

• authorised employees of Web Trade EOOD;
• providers of hosting, technical infrastructure, maintenance and security;
• Google Ireland Limited and Meta Platforms Ireland Limited — only after consent has been given for the relevant category;
• state and regulatory authorities, where the disclosure is mandatory by law.

The providers that process data on our behalf are given only the access that is necessary and are bound by obligations of confidentiality and information security.

We do not sell personal data and do not provide it to other parties for the purposes of their own direct marketing.

7. How long we keep the data

If no contract is concluded following the request, the data from the commercial communication is kept for up to 24 months after the last contact.

If a contract is concluded, the necessary data is kept for the term of the contractual relationship and, after its termination, for the applicable statutory periods, including for the fulfilment of accounting obligations and the defence of legal claims.

The data processed on the basis of consent to measurement or advertising is processed until the consent is withdrawn or until the lifetime of the relevant technology expires, whichever occurs earlier.

The data may be kept for a longer period where this is necessary for the fulfilment of a legal obligation, the handling of a complaint, the establishment of an infringement or the defence of legal claims.

8. Data submitted by guests through SayFIXED

The guest does not create a profile or a user account and is not required to provide a name, a booking number or contact details.

Through the individual QR code the system identifies the hotel and the room. The guest may indicate the type of problem, add a description and, if they wish, attach photos and a contact, for example an email address.

The provision of a contact is voluntary. It is used solely for communication regarding the submitted report, including in order to give notice that it has been resolved.

When a photo is uploaded, SayFIXED removes the location and device metadata before the photo is stored.

The respective hotel determines:

• the purposes and the legal basis for the processing;
• the persons who have access to the reports;
• the retention period for the reports;
• the retention period for the voluntarily provided contact details.

SayFIXED carries out the automatic erasure of the contact details in accordance with the schedule set by the hotel and the applicable limits of the platform.

For information about the specific periods and rules, the guest should consult the privacy policy of the respective hotel.

9. Is the provision of data mandatory

The fields in the form marked as mandatory are necessary in order for us to review the request and to contact you. Without them we cannot process the pilot request.

The provision of a city, a country, a phone number and an additional message is voluntary.

The provision of a contact by a guest when submitting a report through SayFIXED is also voluntary.

10. Your rights

Under the conditions provided for by law, you have the right:

• to obtain information as to whether we process your personal data;
• to obtain access to it;
• to request the rectification of inaccurate or incomplete data;
• to request erasure;
• to request restriction of the processing;
• to object to processing based on legitimate interest;
• to receive the data you have provided in a structured, commonly used and machine-readable format, where the right to data portability is applicable;
• to withdraw a consent you have given;
• to lodge a complaint with the competent supervisory authority.

For data provided through the website and the pilot form, you may exercise your rights at office@say-fixed.com.

Where the request concerns a report submitted through the system of a particular hotel, you should contact the respective hotel as the controller of the data.

You have the right to lodge a complaint with the Commission for Personal Data Protection, the Bulgarian supervisory authority.

11. Automated decision-making

We do not use the data from the form for decisions based solely on automated processing which produce legal effects concerning you or similarly significantly affect you.

12. Changes to this Policy

The Policy may be updated in the event of changes to the platform, to the providers used or to the applicable legislation. The current version is published on this page.