Security policy and protection of personal data
Plan C Ltd. is a personal data administrator within the meaning of the Personal Data Protection Act (PDPA).
You can contact us at the address of registration in the Commercial Register: Sofia 1111, 2 Golash Str., Bl. 1, phone: +359 2 971 2007.
Data Protection Officer: Eng. Robert Künstler, email@example.com.
Data and purposes for processing and on what legal basis we process them
Depending on the specific goals and grounds, Plan C Ltd. processes the following data individually or in combination with each other:
Data provided by you, necessary for identification and fulfillment of the contractual obligations of Plan C Ltd. and the client:
- Names, PIN or personal number of a foreigner, address, telephone and / or e-mail address for contact with you, or a contact person specified by you;
- Names, PIN, address and other data of your proxy, specified in the document with which you have authorized him to represent you before Plan C Ltd.;
Data prepared and generated by Plan C Ltd. in the process of providing the services / goods:
- client number, detailed references to monthly bills / invoices and amount of the liabilities contained in them;
- IP address when visiting our website;
- information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including e-mail, letters, information about your requests for troubleshooting, complaints, requests, complaints and other feedback that we receive from you;
Objectives and legal grounds for the processing of personal data
Data processing, which is necessary for concluding or fulfilling the contract for purchase of goods, electronic services.
Plan C Ltd. processes your data for the following purposes:
- Identification of a client when: concluding a new or amending an existing contract for electronic communications services, concluding a contract for the purchase of a service or device;
- Explanations for the used services and the subscription plans, payment of bills and addressing of complaint / complaint. Customer identification is performed through all commercial and communication channels - company offices, electronic contact form, representatives and distributors of goods and / or services, distance selling;
- Updating of your personal data or of the information about the purchases made by you and / or the used services according to your request for correction / change of data / services;
- Checking the volume and type of customer consumption at your request / complaint / dispute or in order to protect customers and Plan C Ltd. from atypical trafficking and shock accounts (fraud and abuse by third parties) - current account;
- Remaining services included;
- Invoice value;
- Clarification of invoices / monthly fees and provision of references for used services;
- Preparation of proposals for concluding distance and off-premises contracts, sending a courier shipment with pre-contractual information and a draft contract;
- Transaction cancellation service;
- Servicing and responding to customer complaints / inquiries / complaints;
- Adjustments of amounts due if justified;
- Technical assistance for electronic servicing of electronic invoices, detailed reports and in case of forgotten PIN / PUK code; stopping / reactivating a lost / stolen / damaged card; call restrictions; bans and authorizations of services;
- Technical maintenance and elimination of damages and any technical problems - on site and through remote access to the equipment for using the service. Recovery of services suspended due to non-payment;
- Payment of bills, rescheduling, deferral of amounts due;
- Checking the technical feasibility of providing a service;
- Warranty and service of devices;
- Performing processing by data processors - assignment, reporting, acceptance, payment;
In fulfillment of its legal obligations, Plan C Ltd. processes your data for the following purposes:
- Preparation of proposals for concluding distance and off-premises contracts, sending a courier shipment with pre-contractual information and a draft contract; cancellation service;
- Providing information about the client and purchases made by him and / or services used by him upon an officially submitted inquiry / request / inspection by a competent authority;
- Issuance of invoices, preparation of a detailed report on the consumption of services;
- To perform tax and social security control by the relevant competent authorities;
Plan C Ltd. processes your data for the purposes of our following legitimate (legitimate) interests: Processing the data from your accounts / invoices for other purposes, compatible with the original purpose of their collection and providing as a reliable analysis of the variety of our products and services, and an assessment of their usefulness to consumer demand.
Categories of third parties that access and process your personal data
Personal data processors who, on the basis of a contract with Plan C Ltd. - process your personal data on behalf of Plan C Ltd. or have direct / indirect access to your personal data:
- Transport / courier companies in order to fulfill our contractual obligations for delivery of contracts on paper and / or purchased / repaired goods;
- Persons who, upon assignment of Plan C Ltd., maintain equipment and software used for processing your personal data;
- Persons providing services for maintenance of terminal devices;
- The banks servicing the payments made by you;
- Persons providing consulting services in various fields;
Other personal data controllers to whom Plan C Ltd. provides your personal data, processing your data on its own basis and on its own behalf
Competent authorities, which by virtue of a normative act have the authority to require Plan C Ltd. to provide information, including personal data, such as - a Bulgarian court or a court of another country, various supervisory / regulatory bodies - Consumer Protection Commission, Communications Regulation Commission, bodies with powers for protection of national security and public order.
How long is your personal data stored?
The duration of storage of your personal data depends on the purposes of processing for which they were collected:
- The personal data processed for the purpose of concluding / amending and executing a contract for the provision of electronic communications service shall be stored for the term of the contract and until the final settlement of all financial relations between the parties;
- Personal data processed for the purpose of issuing accounting / financial documents for tax and social security control, such as but not limited to - invoices, debit, credit notices, handover protocols, contracts for the provision of services and devices are stored for at least 5 years after expiry of the limitation period for repayment of the public receivable, unless the applicable legislation provides for a longer period.
- Plan C Ltd. may store some of your personal data, including traffic data in an anonymized form and for a longer period until the expiration of the relevant statute of limitations in order to protect in case of claims of customers in connection with the execution / termination of a contract for purchase of goods and / or provision of services, as well as for a longer period in case of a legal dispute that has already arisen in connection with the above until its final settlement by an effective court / arbitration award.
Rights of the subjects in connection with the processing of personal data from Plan C Ltd.
You have the following rights:
- You can request from Plan C Ltd. information whether and for what purposes we process your personal data with a written application with the content specified in Art. 29 ZZLD.
- Plan C Ltd. is obliged to process your request within 14 days or with a reasoned response, when the request cannot be made within the prescribed period due to objective reasons, to extend this period to 30 days.
- The right to request that your personal data be deleted, corrected or blocked when they are inaccurate or should be supplemented, or their processing does not meet the requirements of the LPPD and the General Regulation for Personal Data Protection;
- The right to object to Plan C Ltd. at any time against the processing of your personal data if there is a legal basis for it;
- The right to withdraw your consent to the processing of your personal data when their processing is based on your consent, namely when processing them for direct marketing of products and services of third parties;
- Right to portability of your personal data;
- The right not to be subject to a fully automatic solution.
Can you refuse to provide personal data to Plan C Ltd. and what are the consequences
In order to conclude a contract with you and to provide you with the requested services in accordance with our legal obligations, Plan C Ltd. needs certain data.
Failure to provide the following information prevents Plan C Ltd. from concluding a service/goods contract with you:
- three names, PIN or personal number of a foreigner, address, telephone and/or e-mail address for contact with you, or a contact person specified by you;
- three names, PIN, address and other data of your proxy, specified in the document with which you have authorized him to represent you before Plan C Ltd.;
- shipping address.
Use of pages of Plan C Ltd. on the Internet
In order to increase efficiency, the electronic platform of the site uses specific data files such as cookies.
What are cookies and why are they used?
Cookies are small text files for temporarily storing information about a user's actions, preferences or other activity when visiting a website. They are stored on the computer or mobile device used by the user for a certain period of time, depending on their type.
Cookies help make the website more user-friendly, as it saves users the need to enter their preferences every time they visit the site or go from one page to another.
Cookies allow the website to function smoothly, monitor for irregularities and identify opportunities to optimize the way it provides information and communicates with users.
Types of cookies. The site uses one or more of the following types of cookies, depending on their degree of need:
Systemically required cookies. These are cookies, without which the functioning of the site is impossible or is put at high risk.
These include cookies for navigating the website, saving the completed information when passing between the various steps, as well as when logging in or registering.
Cookies are also systematically required to provide control over the security of the connection and protection against unwanted external interference.
This type of cookie is often defined as temporary or session, as it is stored temporarily and disappears after closing the browser session.
Functionality cookies. This category of cookies serves to make it easier for the user to use the website and to comply with the individual preferences of the user.
Functionality cookies include cookies for device recognition, saving language and font size preferences, and more.
These types of cookies can be stored for a longer time on the device, they can be used in more than one browser session and are called persistent.
Third party cookies for efficiency, analysis and advertising. Analytics cookies are used to collect statistical information on the basis of which general conclusions and recommendations can be made about the effectiveness of the site in view of the goals of users, as well as in view of marketing and advertising purposes.
Such statistics include the number of users per page, the most visited pages, the sources of the visit, the time spent on the page, errors and more. These cookies allow you to collect anonymous information about 8 ways in which users navigate the website and the difficulties they may experience.
For better accuracy, the site uses well-established Google Analytics analytics tools.
Please note that blocking cookies will affect the way the website works and may lead to malfunctioning of the site.
Links. A site or mobile application may include links to other websites that are beyond our control. We are not responsible for the protection of personal data or the content of these websites, but we offer these links to make it easier for our visitors to find more information on specific topics.
Further verification as an administrator whether they can be stored for a longer period in order to exercise our legitimate interest? - I think that these are data like everyone else and the provisions above apply to them.