GENERAL TERMS AND CONDITIONS

I. SCOPE AND CONDITIONS OF THE LOYAL CUSTOMER PROGRAM

1.1. The present program was developed by PALMS MERKUR CASINO.BG EOOD, with UIC 201710165 (hereinafter referred to as Palms Merkur Casino or the "Company") and is focused on adult customers of the catering and entertainment facilities of the Company. It is related to registration and analysis of the orders they make as members of (participants in) the LOYAL CUSTOMER PROGRAM for themselves or for their family members. The aim of the LOYAL CUSTOMER PROGRAM is, on the one hand, to provide bonuses to the Company's customers who choose the Company's restaurants for their daily meals and / or entertainment and organize family celebrations and events, and, on the other hand, to analyse and study consumer trends among the Company's customers (choice of product categories, number of visits, choice of product types, reaction to general and special offers, etc.), in order to improve the management of the Company's customer base and provide products and services that fit well with this customer base.

1.2. Any natural person who has reached the age of 18 may receive a Client Card under the LOYAL CUSTOMER PROGRAM of the Company.

1.3. The Client card entitles the participants in the program to discounts and bonuses when consuming food / without drinks /, on the spot in the restaurants of the Company, located in Grand Hotel Millennium-Sofia, as follows:

Asian restaurant 888 Taste Show Asian Cuisine

Mediterranean restaurant San Remo Mediterranean Cuisine

Sports and piano bar Black & White Sport and Piano Lounge

hereinafter referred to in these General Terms and Conditions as “the Restaurants”.

1.4.The present General terms and conditions, valid for use of the Client card under the LOYAL CUSTOMER PROGRAM of the Company, are available in the Restaurants of the Company, and in case of change in the terms and conditions each client will be notified at the e-mail address indicated by him/her.

2. ISSUANCE AND USE OF A CLIENT CARD

2.1. Each Client card is and remains the property of the Company and its holder is obliged to return it upon request.

2.2. The Client card is personal. Giving it to someone else to use it in any way is prohibited.

2.3. Receipt and activation of the Client card, which is accompanied by submitting an application-declaration for the personal data of its holder, is done on the spot in each of the restaurants of the company.

2.4. The participant has the right to use his / her Client card in each of the Restaurants, for orders on site and in accordance with the conditions set by the Company and for which the participant is informed.

2.5. The Client card is not a credit or a debit card. The Participant may not perform financial transactions using the Client card, except for the privileges that can be used according to the terms and conditions set and announced by the Company.

2.6. In order to be able to enjoy the privileges of the card, the customer should present it to the staff servicing him in each of the Restaurants, stating the preference, desired by him/her.

2.7. Upon receipt of the Client card, the participant receives a discount determined by the Company, but not less than 10% / ten per cent / discount of the value of a food order made by him/her in each of the Restaurants of the Company, listed in item 1.3. No discount is applied on the value of alcohol and soft drinks consumed.

2.8. In addition to the discount under Article2.7. above, additional percentages (not less than 10%) are accumulated on the card in the form of bonus points, and 1 (one) bonus point is equal to BGN 1 (one), actually paid for an order in the Restaurants.
For example, with a bill of BGN 100, depending on the level of the card he / she holds, a customer receives a discount of, for example, 10% and pays BGN 90 for food consumed by him/her in the Restaurants. Additionally, the customer receives 9 / nine / bonus points, equal to 9 / nine / BGN, which are accumulated in his / her Client card and can be used according to the conditions under item 2.9 below. When a customer has placed an order that is not a round number (for example BGN 10.59), for the purposes of receiving points the amount is rounded down.

2.9. The accumulated bonus points can be used at any time and in any of the Restaurants, reducing or fully paying the bill for the food consumed.

2.10. The Client card, the accumulated points and the right to a discount cannot be exchanged for money. According to the number of points accumulated by the participant, he / she will be able to use them only for food consumption in the Restaurants.

2.11. The LOYAL CUSTOMER PROGRAM is valid only in the Restaurants under item 1.3. and is not valid when ordering food online.

3. CHANGES - VALIDITY PERIOD – TERMINATION

3.1. The Company has the right to terminate this contract with the participant (and / or prohibit the use of the Client card in any way) at any time without pre-notice or justification.

3.2. he Client card gives the holder the appropriate privileges for the period during which the LOYAL CUSTOMER PROGRAM is valid. The company reserves the right to change this term at its discretion and has the right to unilaterally amend / supplement the terms of this agreement, including the system for providing bonuses to the participants, the method for calculation of points and the value of the points accumulated against services, as well as to change / supplement or terminate at any time the LOYAL CUSTOMER PROGRAM in its entirety. The holder of a Client card will be informed about any such change by appropriate means, using the contact details provided by him / her and / or by announcing the change in the Restaurants. The Company is not liable to the participants for such changes / additions or for the termination of the LOYAL CUSTOMER PROGRAM, as by accepting these general terms and conditions the participant declares that he /she is aware that this loyalty program is conducted free of charge by the Company.

3.3. The Company has the right to cancel the LOYAL CUSTOMER PROGRAM card at any time in case it is used in violation of this contract or the law or in case of attempted fraud by the participant. In such cases, all bonus points will be deleted and all privileges will be revoked.

3.4. In case a member wishes to terminate his participation in the LOYAL CUSTOMER PROGRAM, the Company will continue to store his / her personal data for 30 days from the termination of the member's participation, in order to ensure the satisfaction of legal claims of the Company, if any.

3.5. In case of loss, theft or damage, the Client card can be replaced only in the Restaurants of the Company.

4. TERMS AND CONDITIONS FOR EXCHANGE OF BONUS POINTS FROM THE LOYAL CUSTOMER PROGRAM

4.1. The participant has the right to exchange points accumulated by him / her for a discount, if the balance of accumulated and available points in his / her client card is equal to or greater than the value of the bill made by the participant for food consumption in any of the Restaurants. For this purpose, the participant will be able to calculate the total number of points that have been accumulated and available. The exchange of bonus points is done by effectively deducting (subtracting) them from the issued fiscal cash receipt / invoice. Participants are not allowed to replace part or all of their accumulated points with money, or to exchange these points for money.

4.2. The participant can deduct the accumulated bonus points from the bill for consumption of food made in each of the Restaurants of the Company, at any time by stating that he / she wants to exchange the respective points. Loyal customer points cannot be used to receive discounts on service prices.

4.3. In each exchange of points against food consumption, the corresponding number of points is deducted from the total number of available points of the participant.

5. PERSONAL DATA PROTECTION POLICY

5.1. Legal grounds to carry out data processing, notification and updating.
PALMS MERKUR CASINO.BG EOOD, with UIC 201710165, registered office and address of management: the town of Sofia, 7 Kukush Str., is an Administrator of the personal data of the participants in the LOYAL CUSTOMER PROGRAM and administers the processing of their personal data on its web pages and in its Restaurants.

The Company informs the participants in (the members of) the LOYAL CUSTOMER PROGRAM and they confirm that they are informed about the following:
а/ For the processing of the personal data of the participants, as described below, the Company refers to the following legal grounds:

Execution of the contract – in order to achieve the objectives of this contract and of the Client card, namely to provide bonuses to participants by way of bonus points and discounts in connection with food consumed by them in the restaurants and, as well as to research and analyse the consumer trends, it is necessary to process personal data provided by the participants upon registration in the LOYAL CUSTOMER PROGRAM, as well as to process data regarding purchases.

The Company also reserves the right to provide regular information to participants by contact via phone, mail, email, SMS or any other applicable means of communication in view of the contact details of the participant, duly obtained in connection with the registration in the LOYAL CUSTOMER PROGRAM for its products and services within the framework of the commercial relationship and provided that the participant does not object to such communication. The provision of such information may include details on promotions, events and / or offers and / or games, communication to conduct a survey in order to improve the products and services provided to participants, as well as other promotional activities and services, and pursuit of other similar goals.

Legitimate interests: certain ways of processing personal data are necessary in order to improve the services provided by the Company (processing of statistical and non-identifying information), to identify attempted fraud or use of customer cards in breach of this agreement or the law, as well as for protection of the legitimate interests of the Company.

Consent: Participants are invited to give their explicit, unambiguous and free-will consent for individualized analysis of their behaviour as customers in order to send them, with or without human participation, commercial correspondence in the form of personalized messages and offers of the Company that meet their preferences and correspond better to their respective profiles.

5.2 Processing and types of personal data - Rights of the participants

a/ Processing of personal data. The Company will process the personal data of the participants, provided by them in the respective application or updated in accordance with the above, in order to provide the services of the LOYAL CUSTOMER PROGRAM.

b/ Types of personal data: In particular, the personal data that each participant provides when registering in the LOYAL CUSTOMER PROGRAM are the following

MANDATORY FIELDS: Name, surname, email.
OPTIONAL FLIGHTS: Phone number.

c/ The types of personal data processed by the Company, with respect to the purposes of processing, are the following:

In order to fulfil the contract (in order to collect points and provide bonuses to the participants in the form of points and privileges in connection with their orders, to convey customer satisfaction surveys and research and analysis of general customer trends) regarding the LOYAL CUSTOMER PROGRAM, the following personal data can be processed by the Company:
Name Surname Mobile phone number Email address (e-mail)
In order to analyse their individual behaviour as customers, with the aim to send them, with or without human participation, commercial correspondence containing personalized messages and offers of the Company that meet their preferences, which better correspond to their profile and preferences, Smart Organic AD will process in addition the following data related to the participants:

Frequency of visits
Demographics
Participation in promotional events

5.3. Participants are informed that their personal data may be processed by the Company even without their consent, in case of fulfilment of legal obligations, such as when required by the tax authorities for inspections or in order to comply with obligations as well as when taking into consideration of the legitimate interests of the Company, for example in cases of lawsuits and proceedings before administrative or judicial bodies.
The participants are also informed that in order to carry out the communication between Smart Organic AD, the latter will process the contact data provided by the participants. In addition, in case of communication of a change in the terms of the LOYAL CUSTOMER PROGRAM, this can be done via SMS / viber / email to the participants, by using a link, etc.; the IP address of the electronic device of the participant (mobile telephone, tablet, computer, etc.) may be registered as proof that the participant has received the notification.

5.4. Recipients of data: Depending on their respective responsibilities and tasks with regard to the purposes of processing described above, recipients of the necessary personal data about the participants may be:

a/ The respective responsible employees of the Company.

b/ Tax authorities, inspection bodies, etc.

When collecting and processing the personal data of the participants, the employees of the Company act in full compliance with the provisions of the General Regulation for Personal Data Protection 2016/679, as well as with the applicable national legislation on personal data protection.

5.5. Rights of data subjects: Each participant, as a data subject, may exercise, at any time, the rights set out by the General Regulation on Personal Data Protection 679/2016, and in particular - those provided in Art. 12-23, as well as the rights provided by the national legislation of the Republic of Bulgaria, namely:

a/ the right to receive information and access to the data processed by the Company;

b/ the right to limit the processing;

c/ the right to correct or delete some or all personal data ("right to be forgotten");

d/ right of objection, i.e. to oppose to the processing of personal data;

e/ right to data portability.

Participants in the LOYAL CUSTOMER PROGRAM may exercise the rights described above in the following ways:
Regarding the right / obligation of access and corrections of personal data, the company provides the participants in the LOYAL CUSTOMER PROGRAM with the opportunity to review / correct / update their personal data:

by sending a request to the following e-mail address: dpo@pmrcasino.com
by sending a letter to the Company at the following address:
7 Kukush Str., Sofia, Bulgaria (To the attention of the DPO / Data Protection Officer)

Each participant in the LOYAL CUSTOMER PROGRAM has the right to withdraw his / her consent at any time and in connection with any processing performed on the basis of their consent, without compromising the legality of the processing before withdrawing the consent.

Withdrawal of consent may be exercised by submitting a request to the e-mail address .................. or by letter to the Company at the following address: 7 Kukush Str., Sofia, Bulgaria (to the attention of the DPO / Data Protection Officer).

When a participant has exercised any of the above rights, the Company will take all possible steps to satisfy his / her application within one (1) month from the date of its submission. In this case, the participant is informed that some necessary personal data / as a minimum / will be retained to ensure the legitimate interests of the administrator and other legal grounds.

An application for deletion of a participant from the LOYAL CUSTOMER PROGRAM can be made by sending an email or letter to the Company at the following address: 7 Kukush Str., Sofia, Bulgaria (to the attention of the DPO / Data Protection Officer).

5.6. Time limit for storage of personal data: the data of the participant will be stored and processed by the Company until deactivation of the LOYAL CUSTOMER PROGRAM card by the participant, or for respective processing of the data on the basis of consent - until withdrawal of the consent. However, some necessary personal data concerning the participant's purchases, as well as notifications, consent and withdrawal of consent may be retained as information for the participant in order to provide evidence of the lawfulness of the Company's data processing and for protection in legal disputes between the parties or on other applicable grounds (for example, to comply with certain legal obligations).

5.7. Special category of data: the participants in the LOYAL CUSTOMER PROGRAM are informed that the Company does not collect and does not require the disclosure of sensitive personal data (special category of data) for the purposes of membership in the LOYAL CUSTOMER PROGRAM.

5.8.Obligation of transparency: For any information regarding personal data and their processing and protection, the participant may contact the Data Protection Officer of the Company by e-mail dpo@pmrcasino.com

5.9.If you are not satisfied with any aspect of the collection and processing of your personal data, you have the right to file a complaint with the relevant Supervisory Authority. The Supervisory authority of the Republic of Bulgaria is the Commission for personal data protection, address: 1592 Sofia 2 “Professor. Tsvetan Lazarov" Blvd., GPS coordinates: N 42.668839 E 23.377495. Centre for information and contacts - tel. 02 / 91-53-518, e-mail:kzld@cpdp.bg, web page: www.cpdp.bg

5.10. Technical and organizational security measures: The Company, the persons hired to process personal data, as well as its representatives / partners, who are entrusted with the implementation of relevant responsibilities and tasks, apply the appropriate technical and organizational measures for the best possible protection of personal data against any incident or unlawful damage or loss, alteration, illegal disclosure and access to them, as well as against any unlawful processing of personal data (including remote access), including ensuring the restoration of access to personal data (as far as possible). These measures aim to ensure a level of security to minimize the risk to the data, taking into account in all cases the relevance of the data, the development of technologies, implementation costs and the nature, scope, context and purposes of the processing, while at the same time procedures for regular testing and evaluation of the effectiveness of these technical and organizational measures are applied. In any case, the Company, the persons hired to process personal data, as well as the relevant representatives and partners entrusted with the implementation of relevant responsibilities and tasks, are bound by an obligation of confidentiality, thus they are obliged to keep the personal data of the LOYAL CUSTOMER PROGRAM participants confidential and not to disclose them or allow third parties to access them without prior notice to the participant, except as expressly provided by law.

The Company declares that the personal data of the participants will not be used for any purposes other than those described in these terms and conditions, unless prior notice is given and, where necessary, consent is obtained.