In order to prepare an offer, draft a contract, contract implementation or in the context of other relationships, we, Balkantel Ltd. process personal data in order to provide the requested by the customers products and services and which Balkantel Ltd. manufactures and provides, both to fulfill all its obligations and to benefit from the rights as per the legislation.
Balkantel Ltd. processes personal identification data, details for offer preparation, contracts, invoices, stock receipts, bills and other personal data in order to comply with obligations provided for in a regulatory act, such as:
Balkantel Ltd. processes personal data only after prior consent. Consent is a separate ground for processing the personal data of the data subject and the purpose of the processing is specified therein and is not covered by the objectives listed in this policy. In the event that consent is given and until it is withdrawn or terminated in any contractual relationship:
Main personal data includes names, gender and age group, address (permanent address).
When processing personal data and the other described data for the purpose of providing products and services, for their payment, for the implementation of customer orders for products or services, and in order to fulfill our statutory obligations, such processing is mandatory for the performance of these objectives. Without this data, we could not provide the relevant services. In the event that we are not provided with the identification data we could not enter into a product or service contract;
Data processing agreements provided by data subjects may be withdrawn at any time. Withdrawal of consent has no effect on the performance of contractual obligations of Balkantel Ltd., if this withdrawal does not concern the performance of agreed activities. In any case where the withdrawal of personal data will affect the performance of activities agreed between the data subject and Balkantel Ltd., the data subject shall be informed how far this will affect the agreed activities, even if this withdrawal may terminate the contracted activities for which the data subject shall be notified.
If the data subject withdraws his / her consent to the processing of personal data for any or all of the ways described above, Balkantel Ltd. will not use personal data and information for the purposes set out above. Withdrawal of consent does not affect the lawfulness of consent-based processing prior to its withdrawal.
Balkantel Ltd. has large portfolio of products and services available. When giving consent to data processing, this consent applies to all products and services that the customer uses.
Withdrawal of personal data when is related to the preparation of offers, conclusion of contracts, preparation of documents may lead to the impossibility to the performance of these actions. For any withdrawal of personal data, the data subject will be notified to what consequences it may lead, according to customer relationships with Balkantel Ltd.
In order to withdraw a given consent, it is necessary to notify Balkantel Ltd. by the publicly known contact details relating to the personal data management.
The basis for the processing of personal data is Article 6, Paragraph 1 of Regulation (EU) 2016/679.
By adopting the general terms and conditions of this policy when submitting to the controller information, containing personal data or upon conclusion of a written contract between the data controller and the data subject, a contractual relationship is created on the grounds of which the controller processes personal data, namely: Article 6, Paragraph 1, b. (b) of the Regulation. The data for sending newsletters, newsletters, marketing information, etc. are processed on the basis of the explicit consent given by the data subject – Article 6, Paragraph 1, b. (a) of the Regulation.
Basis for the data processing: You have given explicit consent to the processing of your personal data for one or more specific purposes – Article 6, Paragraph 1, b. (a) of GDPR.
The controller shall not collect or process any personal data that pertains to the following:
Electronically collected and processed data: data processed in an electronic communications network for the purpose of transmitting, distributing or exchanging electronic content, including data used to track and identify the source and destination of the communication, location data and device type generated in the context of the provision of electronic communications services, as well as date, time and type of communication.
Data analysis: detailed analysis is an analysis method that allows the processing of large volumes of data through statistical models and algorithms and others, which involve the use of network and personal data as well as the processes of aliasing and anonymizing them in order to retrieve information about trends and different statistical indicators.
Partner/s: these are companies with which Balkantel Ltd. has concluded partnership agreements and which provide various products and services.
Balkantel Ltd. uses personal data for identification, preparation of offers, invoices, bills, and any other documents related to our legitimate interest to conduct a basic analysis in order to tailor the products or services we offer to individual customer needs and to offer new products / services satisfying them.
In rare cases, Balkantel Ltd. processes personal data for static purposes, this means for analyzes where the results are only generalizing and therefore the data are anonymous – for example, in order to evaluate our market performance, our financial indicators, marketing information, etc. Identifying a specific person from this information is impossible.
For the processing of personal data, we use partially automated algorithms and methods to constantly improve our products and services in order to ensure our customers’ privacy at Balkantel Ltd., for adapting our products and services to customer needs in the best possible way or for calculating commercial and other discounts. This process is called profiling. Balkantel Ltd. uses partially automated algorithms to determine client rating by performing initial and / or ongoing client ratings. For these purposes, Balkantel Ltd. uses client master data. The processing algorithm aims to provide assessment of customer commercial and other discounts. This partial automated processing is performed using data analysis.
To ensure adequate data protection for company employees and the personal data of their customers and partners, Balkantel Ltd. shall apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as best practices, etc.
The company has implemented structures on prevention of security abuses and breaches, as well has designated a data protection officer as well and a team for data protection, who support the processes on data protection and ensure the data security.
For the purpose of maximum security in the processing, transfer and storage of personal data, additional security mechanisms such as encryption, pseudonymisation, etc. can be used.
After the termination of the contract, as a rule in Balkantel Ltd., the use of personal data for the purposes of the contractual relationship is terminated, but the data are not erased, prior a two years expired period from the contract termination or of the final settlement of all financial obligations and expiration of the statutory obligations for data storage such as obligations under the Electronic Communications Act, storage and provision of information for the purposes of detecting and investigating crimes, obligations (6 months), under the Accounting Act for the storage and processing of accounting data (11 years), the expiry of the statutory limitation periods (5 years) laid down in the Law on Obligations and Contracts, the obligation for information provision to the court, the competent governmental bodies and on other grounds, provided for in the current legislation or the laws concerning employment relationships (50 years).
In applying this policy, it is accounted that personal data will not be erased or anonymized if they are necessary for pending juridical proceedings, administrative proceedings or proceedings to deal with your complaint in front of us.
In some cases, personal data can be anonymized. Anonymisation is an alternative to data erasure. In the case of anonymisation, any personal identifiable elements/ elements allowing the identification of the data subject are irrevocably erased. There is not a legal obligation for the erasure of the anonymized data because they do not constitute personal data /the data anonymisation is performed by replacing the personal data by an anonymized identifier of the data subject – for example, replacement of the names by a numeric-alphanumeric identifier/.
Balkantel Ltd. provides personal data to third parties in exceptional cases, the main purpose being to offer quality, fast and comprehensive service. We do not provide personal data to third parties before to be assured that all technical and organizational measures have been taken to protect these data and strict controls are in place to meet this goal. In this, Balkantel Ltd. remains responsible for the confidentiality and security of your data.
Balkantel Ltd. provides personal data to the following categories of receivers (personal data controllers):
Persons, data processors from the name of Balkantel Ltd.:
In the event that the users of the Balkantel Ltd. ‘site (s) want to prevent Google from analyzing the data, the following settings should be performed:
Google Conversion Tracking allows us and Google to recognize that someone has clicked on our Google ad and then has been redirected to our site. However, we cannot see which other web pages you have loaded. The information gathered through Google Conversion Tracking is solely for the purpose of compiling statistics on the success and use of our AdWords advertising campaigns. However, we do not collect or receive information allowing users to be personally identified.
It is possible that the site / sites of Balkantel Ltd. contain links redirecting to the web page of other sites. These links serve as an online presentation of the newsletter, but also provide an opportunity to stop receiving it and do not participate in the process of managing personal data.
We take technical and organizational security precautions to protect your data from unwanted intrusions and access to the greatest possible extent. Along with securing our information infrastructure, cryptographic methods are used in all sections. To prevent your personal data from being misused from third-party, the information you have provided is transferred and verified in encrypted form using the SSL (Secure Socket Layer) protocol. You can recognize this in your browser’s progress bar on the padlock symbol, which is locked and the Internet address starts with https.
Modern sites use different systems to analyze and improve the delivery of goods and services to users, and it is not possible to describe them in detail. If you have any concerns about the information that is collected from our site, we recommend that you use the Incognito browser option of Google Chrome or Private Browsing of Firefox.
Balkantel Ltd. is a commercial company, duly registered in accordance with the requirements of the Bulgarian legislation, with headquarters and address for correspondence: 68 Bratya Bukston Blvd., 1618 Sofia, Bulgaria, Balkantel Building, Phone: +359 2 8500430, e-mail: firstname.lastname@example.org
Information on the competent supervisory authority:
Name: Commission for personal data protection.
Headquarters and address for correspondence: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.
Phone: (+359-2) 915 3 518
Web page: www.cpdp.bg
Right to access to information
The data subjects shall have the right to request:
In case that Balkantel Ltd. processes incomplete or inaccurate/erroneous data, the data subject shall have the right at any time to request:
At any time, data subjects shall be entitled to:
The data subject shall have the right to obtain restriction of processing where one of the following applies:
The data subject shall have the right to receive the personal data concerning him or her, which they have provided to Balkantel Ltd. in a structured, commonly used and machine-readable format, if:
In the event that a data subject considers that Balkantel Ltd. violates the applicable regulations, he may contact Balkantel Ltd. to clarify the issue. However, data subjects have the right to lodge a complaint with the Commission for Personal Data Protection.
All requests for access to information or for rectification shall be submitted either personally or by an explicitly authorized, by the data subject person, by a notarized power of attorney. An application may also be submitted electronically, in accordance with the Electronic Document and Electronic Signature Act.
All requests for access to information or for correction shall be submitted either personally or by a person expressly authorized by the person subject to the personal data, by a notarized power of attorney. An application may also be made electronically, in accordance with the Electronic Document and Electronic Signature Act. Balkantel Ltd. shall pronounce on a duly filed request within a period of 30 /thirty/ days of its submission. For an objectively needed longer period – in order to collect all the requested data and if the request seriously hinders Balkantel Ltd., this period may be extended to no more than 90 /ninety/ days from the submission of the application. By the decision of Balkantel Ltd. is granted or denied access and/or requested by the applicant information, but the decision will always be motivated.
For the abovementioned activities contact at e-mail address email@example.com is applicable. In the event, that a data subject considers that the processing performed by Balkantel Ltd. violates the current legislation on data protection or the right of personal data protection, there exist also the possibility to lodge a complaint with the competent supervisory authority /Commission for Personal Data Protection/.
In order to apply current protection measures and to comply with the current legislation, Balkantel Ltd. assumes the responsibility for updating this Policy on personal data protection in the event of a change in the legislation or circumstances that it concerns.
This Policy on personal data protection has been updated for the last time on May 30th, 2018.