Privacy Policy
Information about the Personal Data Administrator:
Administrator: TILKOM OOD
Correspondence address: City of Sofia, PO Box 1528 1 Poruchik Nedelcho Bonchev Str., Republic of Bulgaria
Telephone: +359 2 905 5200
E-mail: office@tilcom-bg.com
Website: https://www.tilcom-bg.com/
Information regarding the competent supervisory body for personal data protection
Name: Commission on Personal Data Protection
Seat and registered office: City of Sofia 1592 2 Professor Tsvetan Lazarov Blvd.
Correspondence address: City of Sofia 1592 2 Professor Tsvetan Lazarov Blvd.
Telephone: 02 915 3 518
Web page: www.cpdp.bg
TILKOM OOD, with UIC: 121871118 (hereinafter referred to as “Administrator”) shall perform its operations in compliance with the Personal Data Protection Law and Regulation (EU) 2016/679 of the European Parliament and the Council dated April 27, 2016 regarding protection of natural persons in relation to processing personal data and regarding the free movement of such data. This information shall have the objective of informing you of all aspects of the processing of your personal data by the Administrator and the rights you have in relation to this processing.
Grounds for collection, processing and storage of your personal data
Article 1. The administrator shall collect and process your personal data in relation to the use of the site https://www.tilcom-bg.com/ and in relation to the conclusion of agreements on the grounds of article 6, paragraph 1, Regulation (EU) 2016/679 (GDPR), and more particularly on the following grounds:
- Your express agreement as a client;
- In relation to the purposes of its activity - wholesale and retail trade of goods and shall not process them additionally in a manner incompatible with these objectives.
- Fulfillment of the obligations of the Administrator under an agreement with you;
- Compliance with a legal obligation, which is applied as regards to the Administrator;
- For the purpose of the legitimate interests of the Administrator or a third party;
Objectives and principles of collecting, processing and storage of your personal data
Article 2. (1) We collect and process of your personal data that you provide us with in relation to the use of the website or conclusion of an agreement, including for the following purposes:
- Providing full functionality in the use of the site;
- In relation to the objectives of its activity - wholesale and retail trade
- Accounting objectives;
- Statistical objectives;
- Protection of information security;
- Securing the execution of the agreement for providing the respective service.
(2) We comply with the following principles in processing your personal data:
- Legality, good faith and transparency;
- Restricting processing objectives;
- Compatibility with the processing objectives and reducing the data collected to a minimum;
- Precision and relevance of data;
- Limiting the storage for the purpose of achieving the objectives;
- Integrity and confidentiality of processing and guaranteeing the appropriate level of security of personal data.
What types of personal data does the Administrator collect, process and store
Article 3. (1) The following operations are performed in relation to the personal data, presented by you:
- Sending a request to the site – the objective of this operation is sending information by the consumer to the Administrator in relation to the request for receiving a particular service. Sending a request is not a mandatory step for using of the site and it shall be accessible without sending an e-mail, which requires presentation of personal data.
- Conclusion from the impact assessment: On the grounds of the assessment performed, the operation “Completing and sending a request form in the site” shall be eligible for performance and shall provide sufficient guarantees for protection of the rights and statutory interests of the data subjects in compliance with the requirements of GDPR.
(2) The Administrator shall process the following categories of personal data and information regarding the following objectives and on the following grounds:
- Your individualization data (e-mail, name)
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- Objective for which the data is collected: Executing a connection with the consumer and sending information thereto and subsequent presentation of services.
- Grounds for processing personal data - by sending a request to the site, you hereby provide your consent for the Administrator to process the personal data, sent by you.
(3) The Administrator shall not collect and process personal data referring to the following:
- Disclosing racial or ethnic origin;
- Disclose political, religious or philosophical beliefs or membership in labor union organizations;
- Genetic and biometric data, data about the health conditions or data about the sexual life or the sexual orientation.
(4) Personal data has been collected by the Administrator by the persons this personal data they refer to.
The Administrator shall not perform automated decision-making using data.
Article 5. The Administrator can use the so-called “cookies” for the purposes of presenting full functionality of the website, which you agree to by using our site. All all times you have the right to control and/or delete the cookies through the settings of the browser you use. Cookies are not personal data and shall not be used for identification of the visitors or the users of the site. Cookies do not represent personal data and shall not be used to identify the visitors and users of the site.
Term for storage of your personal data
Article 6. (1) The Administrator shall store your personal data, provided in relation to the applications sent for a term of 5 years for the purpose of defending the legal interests of the Administrator for court or administrative disputes with the users of the site. Subsequently the Administrator shall apply the due care to delete and destroy all of your personal data without undue delay or anonymize them (i.e. render them in such a manner that shall not disclose your identity).
(2) The Administrator shall inform you in case the deadline for storage of data needs to be extended for the purpose of fulfilling a regulatory obligation or for the purpose of the legitimate interests of the Administrator, or other.
(3) The Administrator shall preserve personal data, which shall be required to be preserved under the laws in force for the particular stipulated term.
Submitting your personal data for processing
Article 7. At its own discretion, the Administrator may submit a portion of or all of your personal data to personal data processes for performance of the purposes of processing which you have agreed to, under compliance with the requirements of Regulation (EU) 2016/679 (GDPR).
Your rights in the collection, processing and storage of your personal data
Withdrawal of your consent for processing your personal data
Article 8. (1) In case you do not wish the personal data provided by you to be processed, you shall have the right at all times to withdraw your consent for processing by submitting a free form request and send it to us by e-mail.
(2) Withdrawal of consent shall not have an effect on the legality of personal data processing which the Administrator has completed until this time.
Right to access
Article 9. (1) You are authorized to request and receive by the Administrator confirmation whether personal data related to you are processed by sending a free form request by e-mail.
(2) you have the right to receive access to the data related to you and to the information referring to the collection, processing and storage of your personal data.
(3) Providing access to the data shall be free, but the Administrator shall retain the right to charge administrative fee in case of repeated or excessive claims.
Right to rectification or complementing
Article 10. (1) At all times you shall be allowed to rectify or to complement the imprecise or incorrect personal data, related to you, by sending a request to the Administrator by e-mail by a free form request.
Right to deletion (“to be forgotten”)
Article 11. (1) You have the right to request from the Administrator the deletion of part of or all of the personal data, related to you, and the Administrator shall have the obligation of deleting them without unnecessary delay, in case any of the grounds listed herein below has been indicated:
- personal data is no longer required for the purpose for which they have been collected or processed in any other manner;
- You have withdrawn your consent, on which processing of the data is based and there is no other legal grounds for the processing;
- You object against processing of the personal data related to you, including for the purposes of direct marketing and there is no legal grounds for processing, which would prevail;
- personal data has been processed unlawfully;
- personal data shall be deleted with the purpose of fulfilling the legal obligation under the laws of EU or the right of a member state, which shall be applied toward the Administrator;
- personal data has been collected in relation to offering services to the information community.
(2) The Administrator shall not have the obligation of deleting personal data if it stores and processes it:
- for the purpose of exercising the right of freedom of expression and the right to information;
- For compliance with a legal obligation which requires processing, stipulated in the law of the EU or the right of a member stage, which shall be applied to the Administrator or for the performance of a task of public interest or in exercising official powers, which have been presented to the Administrator;
- Due to reasons of public interest in the area of public health;
- For the purpose of archiving in the interest of public interest, for scientific or historic studies, or for statistical purposes;
- For the establishment, exercising or protecting legal claims.
(3) In order to exercise your right to be forgotten, it shall be necessary to send an e-mail requesting the deletion of of your personal data, which the Administrator is processing, by submitting a free form request.
(4) After we authenticate the identity of the person who has filed the request and the person the data refer to in compliance with the instructions sent by you, we shall delete all of the data about you that we process, in compliance with paragraph 3.
Right to restriction
Article 12. You have the right to request from the Administrator to limit processing of the data related to you by sending a free form request by e-mail, in case:
- You dispute the precision of personal data, for a term which allows the Administrator to check the precision of the personal data;
- The processing is unlawful, but you do not want personal data to be deleted, but instead limited their use;
- The Administrator no longer needs personal data for the processing purposes, but you request them for the purpose of establishment, exercising or protection of its legal claims;
- You have objected against the processing due to inspecting an inspection about whether the legal grounds of the Administrator shall be prevalent to your interests.
(2) After we have received your request, to the e-mail you have used, we shall send you a letter with detailed instructions about your verification as a consumer of the site and personal data subject, for which a request for limiting the processing has been sent.
(3) After the performance of the verification according to paragraph 2, the Administrator shall resume the processing of your personal data.
Right to portability
Article 13. (1) If you have given consent for processing your personal data or if the processing is necessary for the implementation of the agreement with the Administrator, or if your data is being processed automatically, you shall have the right:
- To request from the Administrator to provide you with your personal data in a readable format and transfer them to another Administrator;
- To request from the Administrator directly to transfer your personal data to an Administrator indicated by you, when this is technically feasible.
(2) You shall have the right to exercise the right of portability by sending us a a request in free form by e-mail, after which the Administrator shall send to the e-mail address you have used to register in the website a letter with detailed instructions about your verification as a user of the site and personal data subject, towards which a portability request has been sent.
(3) After performance of the verification according to paragraph 2, the Administrator shall send to the e-mail indicated by you the data which the Administrator processes for you.
Right to receive information
Article 14. You shall have the right to request from the Administrator to keep you informed about all recipients, the personal data of which correction, deletion or restricting of processing has been requested, has been disclosed. The Administrator shall have the right to refuse to provide such information in case this would not be possible or in case it requires disproportionately high levels of effort.
Right to object
Article 15. At all times you shall have the right to object to the processing of personal data to the Administrator, which refer thereto, including in case such personal data is being processed for the purpose of profiling or direct marketing.
Your rights in case of breach of security of your personal data
Article 16. (1) In case the Administrator has established a breach of the security of your personal data, which may cause high level of risk toward your rights and freedoms, the Administrator shall inform you without any unnecessary delay of this breach, as well as the measures undertaken or the measures that will be undertaken.
(2) The Administrator shall not have the obligation of informing you in the following cases:
- In case the Administrator has undertaken appropriate technical and organizational measures for personal data protection, affected by the breach of security;
- In case the Administrator has taken measures which shall guarantee that the breach shall not result in a high level of risk regarding your rights;
- In case notifying you would require unreasonably disproportionate effort.
Persons your personal data is provided to
Article 17. Personal data presented by you may also be provided to third parties depending on the contractual relations and for the purpose of provision of the requested service. In these cases, the handover shall be the subject matter of appropriate guarantees (for example standard contractual provisions).
Article 18. In case of breach of your rights under the provisions listed hereinabove or under the laws in force about personal data protection, you shall have the right to file an appeal to the Commission on Personal Data Protection as follows:
Name: Commission on Personal Data Protection
Seat and registered office: City of Sofia 1592 2 Professor Tsvetan Lazarov Blvd.
Correspondence address: City of Sofia 1592 2 Professor Tsvetan Lazarov Blvd.
Telephone: 02 915 3 518
Web page: www.cpdp.bg