Version 1.0 · Effective 01.01.2026.
Last updated: 01.01.2026.
1. What data we collect
1.1. Bookings. Name, phone number and, optionally, extra request details (date, time, number of seats, comment).
1.2. Technical data. IP address, device and browser type (User-Agent) — for security and abuse prevention.
1.3. Analytics data and cookies. Visit statistics via the tools listed in section 3 (only after your consent).
2. Purposes and legal bases (Art. 6 GDPR)
- Performance of a request (Art. 6(1)(b)) — processing bookings and providing the club's services.
- Consent (Art. 6(1)(a)) — marketing messages, non-essential cookies and analytics. Consent can be withdrawn at any time.
- Legitimate interest (Art. 6(1)(f)) — security, abuse prevention, technical support and service improvement.
- Legal obligation (Art. 6(1)(c)) — accounting and tax requirements.
3. Recipients and third parties (data processors)
We do not sell your personal data. We share it only with providers required to run the service:
- Telegram (Telegram FZ-LLC) — booking notifications.
- Google (Google Ireland Ltd.) — web analytics (Google Analytics).
- Meta (Meta Platforms Ireland Ltd.) — Meta Pixel for ad-performance measurement.
- Microsoft Clarity (Microsoft Corp.) — user behaviour analytics.
- Ahrefs (Ahrefs Pte. Ltd.) — cookieless web analytics.
- Hosting provider — storage of the website.
Each provider processes the data under its own privacy policy.
4. International data transfers
Some of these providers may process data outside the European Economic Area. In such cases transfers rely on the European Commission's Standard Contractual Clauses or another recognised adequate-protection mechanism.
5. Retention
Booking data is kept for up to 12 months. Analytics data follows the retention of the respective tools. Accounting records are kept for the legally required period.
6. Security
We apply technical and organisational measures: encrypted connection (HTTPS), restricted access to data and abuse detection.
7. Your rights
Under the GDPR and the Bulgarian Personal Data Protection Act you have the right to: access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, objection to processing, and withdrawal of consent at any time. To exercise your rights, email [email protected].
8. California residents (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the CPRA, gives you the right to: know what personal information we collect and how it is used; access and delete your personal information; correct inaccurate information; and opt out of the "sale" or "sharing" of personal information. Tira does not sell your personal information and does not share it for cross-context behavioural advertising in exchange for money or other valuable consideration. We will not discriminate against you for exercising these rights. To make a request, email [email protected]; we may need to verify your identity before we respond.
9. Cookies
We use strictly necessary cookies and — after your consent — analytics/marketing cookies. You can manage consent via the "Cookies" button at the bottom of the site or in your browser settings.
10. Children
The service is not directed at persons under 14.
11. Changes to this policy
We may update this policy. The current version is always available at this address, with the last-changed date shown above.
12. Supervisory authority
You have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP): 2 Prof. Tsvetan Lazarov Blvd, Sofia 1592, phone +359 2 915 3518, email [email protected], website cpdp.bg.
13. Data controller
The controller of your personal data is:
«Е96» ЕООД
UIC: 203505694
VAT: BG203505694
Manager: Taras Matyushkin
Place of business:
Tira gaming club, 8 Morska St, Sveti Vlas
Registered address:
7 Sredna Gora St, Meliya 7, apt 503
8256 Sveti Vlas
Nesebar, Burgas
Bulgaria