Privacy policy
of „А1 Bulgaria“

Information about us

„A1 Bulgaria" EАД (А1 and/or the Administrator), is a company, registered in the Commercial Register of the Registry Agency with UIC 131468980, wtih a domicile and an management address: Sofia city, 1309, st. „Kukush"№ 1, number: *88; 088 123; Fax: +359 88 110 8401; e-mail: customerservice@a1.bg.

Contacts for information from A1 regarding the protection of personal data

А1 Bulgaria EAD

st. Kukush 1, 1309 Sofia

dpo@a1.bg

Data protection official:

K.Dushkov

Our main aim when working with personal data

A1 processes your personal data in order to provide you and your household with better, higher quality and more diverse products and services. We are constantly striving to improve our service and the technical parameters of our network. With these goals in mind, A1 has also built a network of strategic commercial partnerships to ensure that we meet all your needs to the fullest extent when using our product portfolio.

The security of the data you entrust to us is very important to us. It is of great importance to the success of our business and to our public image. We therefore protect your data by implementing all appropriate technical and organizational means at our disposal to prevent unauthorized access, unauthorized or malicious use, loss or premature deletion of information. We only collect and process personal data in compliance with local and European law. We are aware that the processing of your data is linked to a specific reason and cannot be carried out without restriction.

The current „Privacy data policy“ aims to explain how and why we process your personal data

How and why do we use your personal data

To make execute a contract or in the context of a pre-contractual relationship

We process your identification data, traffic data and other personal data in order to provide the products and services you have requested and which you use with us, as well as to fulfil contractual and pre-contractual obligations and to exercise the rights under the contracts concluded with you.

The processing is made to:

  • establishing the identity of the customer or his proxy through all commercial channels;
  • managing and fulfilling your requests for products or services, executing contracts for products and services, including to ensure the signing of contracts and other documents;
  • prepare offers for a cotract;
  • process data by a data processor for contract conclusion, award, reporting, acceptance, payment;
  • prepare and send a bill/invoice for the products and/or services you use with us;
  • provide you with the necessary overall service, and to collect amounts due for products and services used;
  • ensure that your bill/invoice details are consistent with the original purpose for collecting them and for the purpose of producing an overview of our products and services;
  • ensure the maintenance of our network in order to provide quality services as agreed;
  • any technical assistance to maintain the services provided;
  • drafting proposals for distance and off-premises contracts, sending courier services with pre-negotiated information and the draft contract as well as handling cancellations;
  • performing a credit assessment to evaluate your request for services;
  • notifying you of anything related to the products and services you use with us, sending you various notices, notifying you of problems, errors or to respond to any requests, complaints, suggestions you make;
  • analyze customer history and preparation of a customer profile in order to determine a suitable offer for you;
  • protect and ensure the security and integrity of our network, you and our employees;
  • identify and/or prevent unlawful acts or acts in contravention of our terms and conditions of relevant services;
  • evaluate and measure the effectiveness of our advertisements and to offer you advertising content that is relevant to your needs;
  • research and analyze customer usage of our network and our services, based on anonymous or personalized information, to identify key trends, improve our understanding of customer behavior and collaborate with third parties to develop new services for our customers;
  • fulfill providing the warranty and servicing of devices;
  • implement portability of phone numbers;
  • provide the services of a telephone directory and telephone directory inquiry

To comply with regulatory obligations

We process your identification data, traffic data, location data, subscriber billing data and other personal data in order to comply with obligations that are stipulated in a legal act, such as:

  • Obligations to provide information to the Communications Regulation Commission or third parties as set out in the Electronic Communications Act;
  • the performance of obligations in relation to distance selling, off-premises selling as set out in the Consumer Protection Act;
  • the provision of information to the Consumer Protection Commission or third parties as provided for in the Consumer Protection Act;
  • provision of information to the Commission for Personal Data Protection in relation to obligations provided for in the legislation on personal data protection - Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc.;
  • obligations provided for in the Accounting Act and the Tax and Social Security Procedural Code and other related regulations in relation to the keeping of proper and lawful accounting records;
  • provision of information to the court and third parties, in the framework of proceedings before a court, in accordance with the requirements of procedural and substantive regulations applicable to the proceedings;
  • to meet our obligations to provide electronic communications in the event of a crisis of a non-military nature, a "Martial Law" regime, a "State of War" regime or other state of emergency;
  • age verification for on-line shopping;
  • where we have a request from an undertaking providing electronic communications services to obtain information about the existence of unpaid obligations owed by you to them, we process your identification data (Unique Civil Number) and information about the existence of unpaid obligations and these obligations meet the following conditions: a) the total amount of the obligation is 15 per cent of the national minimum wage, and b) the duration of the delay is at least 30 days, and c) the enquired undertakings are not notified of a dispute of the obligation of the end user.

After your consent

In some cases, we process your personal data only with your prior written consent. Consent is a separate basis for processing your personal data and the purpose of the processing is set out in it, and does not overlap with the purposes listed in this policy. If you give us the relevant consent and until you withdraw it or terminate any contractual relationship with you:

  • we make suitable offers of A1 products/services to you by carrying out detailed analyses of your basic personal and network data;
  • make suitable product/service offers to you from our partners by processing your basic personal and usage data.
  • Together with our partners Access Finance and/or KESH CREDIT MOBILE EAD and KESH CREDIT EAD, we prepare tailored offers and proposals for products and services of our partners branded with the A1 logo.

Basic personal data include names, gender and age group, address (permanent address).

Network data: data processed on an electronic communications network for the purpose of transmitting, distributing or exchanging electronic communications content; including data used to track and identify the source and destination of communication, location data and device type generated in the context of providing electronic communications services, as well as date, time, duration and type of communication, TV service consumption data, etc.

Detailed analyzes is a method of performing analysis that allows the processing of large volumes of data by means of statistical models and algorithms and others that involve the use of network and personal data, as well as processes of pseudonymising and anonymising the same, in order to extract information on trends and various statistical indicators.

Partners are companies with which A1 has partnership agreements and which provide a variety of products and services.

Consumption data – aggregated data on consumption of services provided by Mobiltel, including type of service, total number and duration of use

After your consent we process your SSN, three names and permanent address to prepare an external credit assessment.

Data that we process jointly with Access Finance and/or KESH CREDIT MOBILE EAD and KESH CREDIT EAD, after your consent: three names, ID number, data on consumption of mobile telephone services and services from "A1 Bulgaria" EAD, as follows - period of use of services, amount of monthly bills, amount of amounts due by type of service, types of services and products, volume of Internet traffic used, data on type of service, data on consumption of individual types of services, billing period, data on limitation due to non-payment, after your consent to the preparation of individual offers and proposals for products and services of "Access Finance" Ltd. and/or "KESH CREDIT MOBILE" EAD and "KESH CREDIT" EAD, branded with the logo of A1

Consents granted may be withdrawn at any time. Withdrawal of consent has no impact on the performance of A1's contractual obligations. If you withdraw your consent to the processing of personal data for any or all of the ways described above, A1 will not use your personal data and information for the purposes set out above. Withdrawal of consent does not affect the lawfulness of processing based on consent given prior to withdrawal.

We have a large portfolio of products and services on offer. When you provide us with consent to data processing, this consent applies to all products and services you use.

To withdraw the consent you have given, you only need to use the shop network, our website or simply our contact details.

In view of our legitimate interest

We use your identification data, subscriber billing data with our legitimate interest to perform a basic analysis of your data in order to tailor the services we offer to your individual needs and to offer you new services that meet them.

We also process your data for the following purposes of our legitimate interest:

  • To prepare and store statistical information and reports in aggregate form in order to develop and improve our products and services and to improve our customer service.
  • Performing a credit assessment to evaluate your request for service provision, including information about your unpaid obligations to other companies providing electronic communications services, where the obligations meet the following conditions: a) the total amount of the obligation is 15 percent of the national minimum wage, and b) the duration of the delay is at least 30 days, and c) the inquired companies have not been notified of a legal dispute of the end user's obligation, or, if the obligation has been disputed, the claim has been settled.
  • Calculate the number of users for TV services by tracking the viewership of TV channels by our customers for statistical purposes. Information about user behavior on the TV platform through which it provides the Digital TV service. No personal data is processed in this process. The information collected is used in aggregate form to analyze user behavior on the TV platform, allowing us to offer content appropriate to different user journeys and the TV content used. Each user has the possibility to deactivate this setting from the interface of the platform, in the "Privacy Settings" menu, at any time.
  • Auditing by TV content providers - in relation to the performance of the content supply contracts that A1 has entered into; Producing aggregated statistics on our sales, services, customers, network traffic, location patterns that we may also provide to third parties etc.;
  • Customer profiling for direct marketing purposes, including the use of customer credit score results for the purpose of profiling for direct marketing of our own products and services and products and services that we offer in conjunction with our partners.
  • Evaluating the measurement of the effectiveness of our advertising in order to adapt and optimize advertising content;
  • Processing of account/invoice data for other purposes compatible with the original processing purposes to provide analysis of our products and services and assess consumer demand.
  • In-court and out-of-court collections.
  • Collateral by way of suretyship or other means that serves the collection of receivables;
  • Assignment of customer receivables and providing debt information to the assignee.

Processing of anonymized data

We process your traffic data for static purposes, that is, for analyses where the results are only aggregated and the data is therefore anonymized - for example, to represent the movement of large groups of people. It is impossible to identify a specific person from this information.

What kind of data do we process:

data for identification:

  • full name, unique nationality number or identity number of the foreigner, permanent address, identity document a document, including data on the type, number, date, place and authority of issue of the identity document presented;

traffic data(network data)

  • data necessary for the provision of electronic communications services, for billing purposes; data for the preparation of subscribers' bills and for proving their accuracy; data processed in electronic communications networks to determine the geographical location of the terminal electronic communications equipment, including in the case of roaming;

other data:

  • information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:
    • audio recordings of calls made to and from our contact centers aimed at improving service;
    • video recordings of calls that are made to our contact centers in order to provide remote support for technical customer issues;
    • emails, letters, information about your troubleshooting requests, complaints, requests, grievances;
    • other feedback we receive from you;
    • personal contact details - contact address, phone number and contact information (email, phone number), gender, age group;
    • video recordings that are made to improve security by the A1 store network and our sales representatives;
    • preferences about the services we provide to you;
    • credit rating;
    • credit or debit card information, bank account number or other banking and payment information in connection with payments made to A1;
    • other information such as:
      • Customer number, code or other identifier created by A1 to identify subscribers/users;
      • data provided via the company's website and mobile applications;
      • information about the terminal electronic communications device used, the type of device, the operating system used, IP address when visiting our website;
      • Demographic data, household information when you agree to participate in our surveys, prize draws or other feedback you provide to us in relation to the products services you use;
      • other personal data provided by you or a third party when entering into or during the term of a contract with A1 and in particular: full name, unique nationality number or ID number of a foreigner, permanent address of a proxy as stated in a document in which you have authorized him/her to represent them; social networking account details, contact details, contact person; username, password (when registering on A1's website or other similar service); data provided when participating in games, sweepstakes and/or other seasonal or promotional campaigns organized by A1, including through social networks;
      • activity data - data that is processed on the web to record user preferences.

Reference data:

Under the terms and conditions described in the Electronic Communications Act, information to identify the end-user and/or their representative (proxy or legal representative), to ensure the accuracy of the end-user/representative data and to prevent abuse, we may:

  • verify the photograph of the identity document presented, as well as the other identification data of the person, by consulting the information funds for Bulgarian identity documents, with the exception of fingerprints, and the uniform register for foreigners.
  • data to provide information on the existence of your unpaid debts to us other undertakings providing public electronic communications services - your identification data and data on unpaid debts.
  • Where we process your basic personal data and traffic data, and the other data described, for the purposes of providing products and services, paying for them, fulfilling your requests for services, and in order to comply with our regulatory obligations, this processing is mandatory in order to fulfil these purposes. Without this data, we could not provide the relevant services. If you do not provide us with identification data, we would not be able to enter into a product or service contract with you.

Why and how we use automated algorithms

For the processing of your personal data, we use partially automated algorithms and methods in order to continuously improve our products and services to adapt our products and services to your needs in the best possible way or to calculate. This process is called profiling.

We use automated algorithms to determine your credit score by performing initial and/or ongoing credit evaluations to assess your ability to pay when purchasing and using our products and services. The initial credit assessment is performed prior to entering into a contract, in the context of our pre-contractual relationship, and the ongoing credit assessment is performed during the term of the contract. The algorithm aims to assess how likely you are to pay regularly and on time the amounts due for the products and services you use and how likely you are to be insolvent. Where a terminal device is also provided at the time of entering into a contract, we may request information from other undertakings providing public electronic communications services as to whether there are any unpaid debts owed by you to them. The information requested shall be provided in accordance with the terms and conditions detailed in the Electronic Communications Act. In the event of a low credit rating or no rating for you, we may delay signing the contract, terminate the provision of service or request additional payment guarantees. In view of the use of automated algorithms, you have the right to request human intervention in carrying out the assessment or at least to state your objections to the score. More information on credit scoring can be found in the "A1 Bulgaria EAD Credit Scoring Policy" published HERE and available at our stores

How do we protect your personal data

To ensure adequate protection of the company's and its customers' data, we apply all necessary organizational and technical measures provided for in the Data Protection Act, as well as best practices from international standards (ISO 27001:2013, etc.), A1 Telekom Austria Group practices, etc.

The company has established structures to prevent misuse and security breaches and has appointed a Data Protection Officer as well as a Data Protection Committee to support the processes of protecting and securing your data.

In order to maximize the security of the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.

When do we erase your personal data

As a rule, we stop using your personal data for the purposes related to the contractual relationship after the termination of the contract, but we do not delete it before the expiration of one year from the termination of the contract or until all financial obligations have been finally settled and statutory data retention obligations have expired, such as: obligations under the Electronic Communications Act to store and provide information for the purposes of detecting and investigating crime, (6 months) obligations under the Accountancy Act Please note that we will not delete or anonymize your personal data if it is necessary for a pending judicial, administrative or complaint proceeding before us. A1 Bulgaria stores data necessary for payment and for the formation of subscribers' accounts within the time limits set by the applicable legislation.

Your data may also be anonymized. Anonymization is an alternative to data deletion. In the case of anonymization, all personally identifiable elements are irreversibly deleted. There is no legal obligation to delete anonymized data as it does not constitute personal data.

We provide your personal data to third parties as our main aim is to offer you a quality, fast and comprehensive service by making sure that the products and services we offer you meet your expectations. We do not provide your personal data to third parties until we are satisfied that all technical and organisational measures have been taken to protect that data and we aim to implement strict controls to fulfil this purpose. In this case, we remain responsible for the confidentiality and security of your data.

When and why do we share your data with third parties

We provide your personal data to third parties as our main goal is to provide you with quality, fast and comprehensive service while taking care of the products and services we offer to meet your expectations. We do not disclose your personal data to third parties before we make sure that all technical and organizational measures have been taken to guard that data, we strive to have strict control over the fulfillment of this purpose. In this case, we remain responsible for the privacy and security of your data.

We provide personal data to the following categories of recipients (data controllers):

People processing data on behalf of A1:

  • Credit reference agencies for the purposes of initial and ongoing credit assessment;
  • debt collection and/or security companies - debt collection agencies, credit agencies which, through suretyship or other means, service and collect debts;
  • postal operators, with a view to sending items containing contracts, supplementary agreements and other documents and the need to authenticate identity when delivering them;
  • distributors and agents of A1 who act as representatives of the company in the sale of services and products;
  • persons who, on assignment, maintain equipment, software and hardware used to process personal data and necessary for the construction of the company's network and for the performance of various reporting services, payment for services and products, technical support, etc.;
  • persons providing service support for terminal devices;
  • call centers that assist A1 in selling products and services and in servicing customers before and during the contractual relationship;
  • installers - for installation or maintenance to provide the service;
  • persons employed on a civilian contract by A1 to assist in sales, logistics, delivery, etc. processes;
  • Banks to service payments made by you;
  • security companies licensed to carry out private security activities in connection with the processing of video footage from A1's premises and/or the provision of security access to the premises;
  • persons providing services for the organization, storage, indexing and destruction of paper and/or electronic records;
  • persons providing consultancy services in various fields.

People who process your data in his own name

  • Assignees - party to assignment agreements whereby A1 assigns (sells) your outstanding obligations;
  • Competent authorities which by virtue of a statutory act have the power to require the provision of information, including personal data, such as - courts, prosecutor's office, various regulatory authorities such as the Consumer Protection Commission, Communications Regulation Commission, Personal Data Protection Commission, authorities with powers to protect national security and public order;
  • other electronic communications operators, in view of the need to provide electronic communications services for roaming, number portability and interconnection between undertakings;
  • guarantors, where, when a contract for the purchase of a terminal equipment is concluded, the transaction is secured by a guarantee;
  • providers of electronic certification services, where a document relating to the provision of a product or service is signed with an electronic signature;
  • postal operators, where postal services are provided.
  • credit agencies - at the time of credit assessment, when determining credit rating and when assessing deferred payment/leasing.
  • credit institutions - on providing financial product(s)/service(s) branded with the A1 Bulgaria EAD logo as joint administrators with A1 Bulgaria.

When does A1 process personal data for services for his partners

In some situations, we process your personal data for products and services that we provide as a third-party sales agent/partner. In these cases, A1 is acting on a commission from the relevant partner and processing your data in accordance with its rules and requirements, but while maintaining the company's high standards for handling sensitive information and taking all necessary technical and organizational measures to protect the data.

Insurance agent of ALTLAS INSURANCE PPC LIMITED and ALIANZ BULGARIA AD

A1 Bulgaria is the insurance agent of ALTLAS INSURANCE PPC LIMITED, an insurance company registered under the laws of the Republic of Malta and ALIANZ BULGARIA AD, registered in the Commercial Register of the Registry Agency with UIC 040638060.

As a representative of both companies, we offer insurance on their behalf by processing your data for this purpose, which is explicitly stated in the applications and contracts for the respective service, as well as in the explicit information documents for the protection of personal data, which are provided to you at the time of conclusion of the transaction and are part of the respective set of documents.

Sales representative of "PEINETIX" AD

A1 is a sales representative of "PEINETIX" AD, registered in the Commercial Register at the Registry Agency with UIC 131574695 for the provision of the "digital wallet" service to its customers.

As an agent of the company, we offer digital wallet services by processing your data for this purpose, explicitly stated in the applications and contracts for the respective service, as well as in the explicit information documents for personal data protection, which are provided to you at the time of the transaction and are part of the respective set of documents. You can find more information on how PAINETICS plc processes personal data as a data controller here

When A1 also acts as a joint data controller for its partners' services

Credit intermediary of ACCESS FINANCE Ltd.

A1 is a credit intermediary of ACCESS FINANCE Ltd., registered in the Commercial Register of the Registry Agency with UIC 202806978 and as such assists the company in offering the service A1 credit card, A1 quick loan and A1 consumer loan.

The joint administrator "A1 Bulgaria" EAD carries out:

  • Promotion and advertising of the financial products A1 Credit Card, A1 Quick Credit and A1 Consumer Credit provided by Access Finance Ltd. and branded with the A1 logo, including by offering them to its customers through all available communication channels - in-store, through information on websites, the mobile application of "A1 Bulgaria" EAD, short text messages, e-mail, electronic communication;
  • Provision of the possibility to apply to the customers of "A1 Bulgaria" EAD after receiving a short text message and/or by filling in an online application form herevia the web interface or via the mobile application of "A1 Bulgaria" EAD;
  • Accepting applications for an individual A1 credit card offer as a credit intermediary of Access Finance Ltd. Applications are filled out on an electronic device /tablet or computer/ in the stores of "A1 Bulgaria "EAD in front of an employee of the company, who identifies the applicant in person, takes a copy of the identity document and provides the completed application for review and signature by the applicant on an electronic device of "A1 Bulgaria "EAD. The downloading of a copy of the identity document is done solely for the purpose of providing it to Access Finance in our capacity as a credit intermediary for that company and is not used for any other purpose. It sends the signed applications via an integrated system application in a secure environment with an encrypted connection to the system of Access Finance Ltd;
  • Accept applications for credit in its capacity as credit intermediary for Access Finance Ltd. Applications are filled in the mobile application or in the web interface of "A1 Bulgaria" Ltd., available at: here, and in the application process the person provides his/her data: three names, personal identification number, data from the identity document, citizenship, other citizenships, bank account number, education, position held, monthly income, data on car ownership, data on holding a position as a prominent political figure or affiliation with such a category of persons, and in the application process the person provides a copy of the identity document. "A1 Bulgaria EAD, as a credit intermediary of Access Finance Ltd, collects and provides all the information completed in the application process, including the attached identity documents and consents through an integrated system application in a secure environment with an encrypted connection to the system of Access Finance Ltd;
  • Accepting requests to receive individual offers for a financial product branded with the A1 logo, in which case A1 Bulgaria EAD collects and transmits to Access Finance Ltd. first name, last name, ID number, telephone number and e-mail address;
  • Collecting consent for the transmission of data on the consumption of mobile telephone services and services from "A1 Bulgaria" EAD, as follows - period of use of services, amount of monthly bills, amount of amounts due by type of service, types of services and products, volume of Internet traffic used, data on type of service, data on consumption of individual types of services, billing period, data for limitation due to non-payment identification data (three names, ID number) and contact data (telephone number, e-mail address) transmits them to "AXESS FINANCE" Ltd, with the right for the company to analyze said data and process it automatically, including profiling applicants in order to provide them with individual offers for products and services branded with the A1 logo
  • A1 Bulgaria EAD provides to the partner ACCESS FINANCE Ltd. data on monthly consumption of mobile telephone services and services from A1 Bulgaria EAD on the basis of explicit consent of the customers and informs them in the manner chosen by them about the individual offers for products and services branded with the logo of A1.
  • For the purpose of obtaining an offer to apply for the financial product "A1 Credit Card", the joint administrator "A1 Bulgaria" EAD collects and processes the following personal data of loan applicants of "Access Finance" Ltd.
  • For the purpose of customer service in a call centre by verifying by SSN in connection with a contractual and/or pre-contractual relationship. The check is carried out by entering the PIN in the Interactive Voice Response (IVR) system of A1 Bulgaria EAD by dialing a tone signal from the keypad of the telephone. "A1 Bulgaria EAD requests a reference in the systems of Access Finance Ltd. by the entered unique identifier EIN, as a result of which, if the person is a customer, redirects the person to be served by Access Finance Ltd.

The Joint Administrator Access Finance Ltd:

  • Analysis of monthly mobile phone service consumption data based on the explicit consent of the customers of A1 Bulgaria EAD and provides individual offers for the use of financial products or services branded with the A1 logo;
  • Provides data on the e-mail addresses of the customers of financial products branded with the logo of "A1 Bulgaria" EAD in order to provide the latter with the technical possibility of forwarding from the "My A1" profile to the profile of the respective product managed by "Access Finance" Ltd.
  • The exchange of personal data for the purposes of the processes described above shall be carried out electronically in a secure environment with an encrypted connection, in compliance with technical and organizational measures to protect the information. More information on how ACCESS FINANCE Ltd. processes personal data can be found here: https://my.a1card.bg/gdpr

Credit intermediary of KESH CREDIT MOBILE EAD and KESH CREDIT EAD

A1 is the credit intermediary of "KESH CREDIT MOBILE" EAD entered in the Commercial Register at the Registry Agency with UIC 202376220 and "KESH CREDIT" EAD entered in the Commercial Register at the Registry Agency with UIC 205893155. and as such assists the company in offering the service A1 credit card and A1 quick credit.

  • Promotion and advertising of A1 Credit financial products provided by KESH CREDIT MOBILE EAD and KESH CREDIT EAD and branded with the A1 logo, including by offering them to its customers through all available communication channels - in-store, through information on websites, short text messages, e-mail, electronic communication;
  • Accepting requests to receive individual offers for a financial product branded with the A1 logo, in which case A1 Bulgaria EAD collects and transmits to KESH CREDIT MOBILE EAD and KESH CREDIT EAD: name, surname, ID number, telephone number and e-mail address;
  • Collection of consent for the transmission of data on the consumption of mobile telephone services and services from "A1 Bulgaria" EAD, as follows - period of use of services, amount of monthly bills, amount of amounts due by type of services, types of services and products, volume of Internet traffic used, data on type of service, data on consumption of individual types of services, billing period, limitation data due to non-payment identification data (three names, ID number) and contact data (telephone number, e-mail address) transmits them to KESH CREDIT MOBILE EAD and KESH CREDIT EAD with the right for the company to analyze said data and process it automatically, including profiling applicants in order to provide them with individual offers for products and services branded with the A1 logo;
  • "A1 Bulgaria" EAD provides the partner "KESH CREDIT MOBILE" EAD and "KESH CREDIT" EAD with data on the monthly consumption of mobile telephone services and services by "A1 Bulgaria" EAD on the basis of the customers' explicit consent and informs them in the manner chosen by them about the individual offers of products and services branded with the A1 logo provided by the partner "KESH CREDIT MOBILE" EAD and "KESH CREDIT" EAD.

The joint administrators "KESH CREDIT MOBILE" EAD and "KESH CREDIT" EAD carry out:

  • Analyzes data on monthly consumption of mobile phone services on the basis of explicit consent of the customers of A1 Bulgaria EAD and provides individual offers for the use of financial products or services branded with the A1 logo;
  • Provides data on the e-mail addresses of the customers of financial products branded with the logo of "A1 Bulgaria" EAD in order to provide the latter with the technical possibility of forwarding from the profile "My A1" to the profile of the respective product managed by "KESH CREDIT MOBILE" EAD and "KESH CREDIT" EAD
  • The exchange of personal data for the purposes of the processes described above is carried out electronically in a secure environment with an encrypted connection, in compliance with technical and organisational measures to protect the information.

 

More information on how KESH CREDIT MOBILE EAD and KESH CREDIT EAD process personal data can be found here:

 https://cashcredit.bg/politika-za-poveritelnost-i-zashtita-na-lichni-danni

Your rights in relation to the processing of your personal data

Right of information:

You have the right to ask about information whether and to what extent we process your data

Right to rectification

In the event that we process incomplete or erroneous/incorrect data, you have the right, at any time, to request that we rectify or supplement it.

Right to erasure:

You may request the erasure of personal data relating to you in the event that we process such data without a legal basis. Please note that there may be reasons why the erasure may not take place immediately due to a legal requirement to retain the data.

Right to object:

In the event that we process data for purposes/tasks in the public interest or in the exercise of official authority vested in us, or we have indicated that processing the data for our legitimate interest, you may object to the processing of the data.

Right to complain:

If you believe that we are in breach of applicable law, we ask that you contact us to clarify the matter. Of course, you have the right to lodge a complaint with the Data Protection Commission. You can also lodge a complaint with a regulatory authority within the EU.

Right to object to processing for direct marketing purposes on the grounds of our legitimate interest

Where we process personal data for our legitimate interest, for direct marketing purposes, you have the right at any time to object to processing of personal data relating to you for this type of marketing, which includes profiling insofar as it relates to direct marketing.

Competent data protection authorities:

You have the right to lodge a complaint with the Commission for Personal Data Protection, (Sofia, 1592, Sofia Blvd. Prof. Tsvetan Lazarov № 2 +3592/91-53-518, E-Mail: hkzld@cpdp.bg) within 6 months of becoming aware of the breach, but no later than two years after the breach occurred. In the event of refusal of access to or correction of personal data, you have the right to apply to the Commission for assistance in exercising your rights.

Please inform other users if they use services purchased from you (e.g. staff or family members) about the processing and transmission of your data.

Applications for the exercise of rights must be made in person or by a person expressly authorized by you, by notarized power of attorney. If the application is submitted by post or in writing, without verification of the identity document by a representative of A1, the application must be notarized. An application may also be made electronically, signed with a qualified electronic signature. The application shall contain: a) the name, address, unique nationality number or identity number of the alien or other similar identifier, or other identification data of the natural person; b) a description of the request; c) the preferred form of communication and action under Articles 15-22 of Regulation (EU) 2016/679; d) signature, date of submission of the application and address for correspondence; e) in case of an application by an authorized person, the application shall be accompanied by the relevant power of attorney.

Notification in the event of a personal data breach
Where a personal data breach is likely to pose a high risk to your rights and freedoms, A1 Bulgaria will provide you with proper notification of the security breach.

We do not send a notification if any of the following conditions are met:

  • we have taken appropriate technical and organizational measures to protect your personal data affected by the security breach;
  • we have subsequently taken measures to ensure that the high risk to your rights and freedoms is no longer likely to materialize;
  • individual notification requires efforts that are disproportionate. In such a case, we make a public announcement or take another similar measure so that you are equally effectively informed

Notification in the event of a personal data breach

Where a personal data breach is likely to pose a high risk to your rights and freedoms, A1 Bulgaria will provide you with proper notification of the security breach.

 

We do not send a notification if any of the following conditions are met:

 

  • we have taken appropriate technical and organizational measures to protect your personal data affected by the security breach;
  • we have subsequently taken measures to ensure that the high risk to your rights and freedoms is no longer likely to materialize;
  • individual notification requires efforts that are disproportionate. In such a case, we make a public announcement or take another similar measure so that you are equally effectively informed

Relevance and policy changes

In order to implement the most up-to-date protection measures and to comply with current legislation, we will regularly update this Privacy Policy. If any changes we make are material, we may post notice of the changes on our websites, mobile applications and IVR menu. We invite you to regularly review the current version of this Privacy Policy to keep informed about how we are protecting the personal data we collect.

 

This Privacy Policy was last updated on 20.12.2021.

 

You can find detailed information HERE

FAQ:

This "Privacy Policy" has been prepared on the basis of current legislation.