Terms and Conditions

1. The Service

Smarthoster-bg is a cloud-based platform ("Service") that helps hosts of short-term rental properties in Bulgaria complete the government-mandated ESTI guest self-registration. The Service lets guests scan their identity document from their own phone, syncs booking confirmations automatically, and generates export files for submission to the ESTI portal. Each registered property also receives a personal property site and guest guide page, published publicly online.

If you choose to include personal data in your property's public guest guide or personal site — for example the phone number of a property manager, cleaner, neighbour, or any other individual — you are solely responsible for having a lawful basis for publishing it and for that person being aware it will be made public. We publish exactly the content you enter into these pages and take no responsibility for personal data you choose to make publicly visible through this feature.

2. Account Registration

To use the Service you must be at least 18 years old and have the legal capacity to enter into this agreement on behalf of yourself or the business you represent.

You are responsible for keeping your admin API key confidential and for all activity that occurs using it. If you believe your API key has been compromised, contact us immediately at support@smarthoster-bg.com so we can help secure your account.

3. Subscription and Payment

The Service is free of charge for the first 6 months from the date your account is registered, for every host — regardless of whether you manage a single property or several. This trial period applies automatically; no payment details are required to sign up.

After the trial period ends, continued use of the Service is billed on a pay-as-you-go basis — a per-registration fee, at the rate published on our website at the time, for each guest registration you complete through the Service — plus any applicable VAT, rather than a fixed monthly or annual subscription.

We may change our pricing for future use. If we do, we will notify you at least 30 days in advance at the contact email on your account.

4. Acceptable Use

You agree not to: use the Service for any unlawful purpose; attempt to gain unauthorized access to the Service or other users' data; resell, sublicense, or white-label the Service without our written consent; submit false, fraudulent, or knowingly inaccurate guest data for registration with government authorities; or reverse-engineer, decompile, or otherwise attempt to extract the source code of the Service.

We may suspend or terminate accounts that violate this section, with or without prior notice, depending on the severity of the violation.

5. Guest Data and Your Responsibilities

When you use the Service to collect and process guest personal data (including identity document details) for the purpose of tourist registration, you act as the data controller under the General Data Protection Regulation (GDPR), and Smarthoster-bg acts as your data processor. This Section, together with these Terms as a whole, constitutes our data processing agreement under Article 28 GDPR.

You are responsible for having a lawful basis for collecting this data and for providing your guests with appropriate notice of how their data will be used, consistent with applicable law.

Guest identity data is encrypted at rest and is used by us solely to operate the Service and fulfil the legally required ESTI registration — never for marketing or resold to third parties. We process guest personal data only on your documented instructions as given through your use of the Service's features, except where European Union or Bulgarian law requires otherwise — in which case we will inform you of that legal requirement beforehand, unless the law prohibits us from doing so.

Access to guest data is restricted to the personnel and system administrators who need it to operate the Service, and each of them is bound by a contractual or statutory obligation of confidentiality covering that data.

If we become aware of a personal data breach affecting guest data processed through the Service, we will notify you without undue delay, providing the information reasonably available to us, so that you — as data controller — can meet your own notification obligations to the Commission for Personal Data Protection (CPDP/КЗЛД) and to affected guests within the timeframes required by GDPR.

To provide the Service, we engage the following sub-processors, each under a written agreement imposing data-protection obligations equivalent to those in this Section: Oracle Cloud Infrastructure (OCI), which hosts our servers and database; Cloudflare, Inc. (R2 storage, EU jurisdiction), which stores property photos and check-in videos uploaded through the Service; and, only if you enable Gmail-based booking sync, Google LLC, which we connect to using the Gmail address and app password you provide, solely to read booking-confirmation emails and send notifications you've enabled. By using the Service you authorise our engagement of these sub-processors. We will update this Section if we add or replace one and, for a material change, notify you at the contact email on your account at least 14 days in advance; you may object by terminating your account before the change takes effect.

Guest identity documents are scanned and read entirely on the guest's own device, in their browser — the document photo itself is never uploaded to our servers or shared with any third party. Only the reviewed, structured data the guest confirms is submitted to us.

We will provide you with reasonable assistance, taking into account the nature of the processing, to help you respond to guests exercising their rights under GDPR and to meet your own obligations around data security, breach notification, and data protection impact assessments, to the extent this depends on the Service.

On reasonable written request, we will make available the information necessary to demonstrate our compliance with this Section. As the Service is a shared, multi-tenant platform, we do not permit on-site audits of our infrastructure, but will cooperate in good faith with any review reasonably necessary to verify compliance.

6. Intellectual Property

The Service, including its software, design, and branding, is owned by MAT-DZHI EOOD and protected by applicable intellectual property laws.

Any property descriptions, photos, or other content you upload remain your property. By uploading them, you grant us a non-exclusive, worldwide license to host, display, and publish that content as part of your property's personal site, guest guide, and public showcase listing, for as long as your account remains active.

7. Availability and Warranties

The Service is provided "as is" and "as available." We do not guarantee that it will be uninterrupted, error-free, or available at all times, including where availability depends on the ESTI government portal, Airbnb, or other third-party systems outside our control.

8. Limitation of Liability

To the maximum extent permitted by law, our total liability to you for any claim arising from your use of the Service is limited to the fees you paid us in the three months preceding the claim — or, if the claim arises during your free trial period, to zero. We are not liable for indirect, incidental, or consequential damages.

9. Termination

You may stop using the Service and delete your account at any time. We may suspend or terminate your account for violation of these Terms, non-payment after your trial period ends, or where required by law.

Because we act only as your data processor for guest personal data, we do not retain that data on our own authority after your account is terminated. Following termination, contact support@smarthoster-bg.com to request that we delete or return your account's guest and booking data; unless you ask us to return it, we will permanently delete all guest personal data, and any copies, within 30 days of termination — except where European Union or Bulgarian law specifically requires us (not you) to keep a copy for longer, in which case we will restrict its use to compliance with that law. Any separate legal obligation you have as data controller to keep records of past guests (for example under Bulgarian tourism or tax law) is your own responsibility — export any records you need before terminating your account.

10. Changes to These Terms

We may update these Terms from time to time. If we make material changes, we will notify you at least 14 days in advance at the contact email on your account. Continued use of the Service after that date constitutes acceptance of the updated Terms.

11. Governing Law and Disputes

These Terms are governed by the laws of the Republic of Bulgaria. Any dispute arising from these Terms shall be subject to the jurisdiction of the competent courts in Sofia, Bulgaria, except where mandatory consumer-protection rules provide otherwise.

12. Contact

MAT-DZHI EOOD

Company registration number (EIK): 203449792

Registered address: Sofia, Suhata Reka bl.110 ent.A fl.1 ap.1

Email: support@smarthoster-bg.com