Privacy Policy

Our main ambition when we operate with personal data

PTS Bulgaria Ltd processes your personal data in order to provide you with more versatile products and services. We constantly strive to improve our service. With a view to this purpose, PTS Bulgaria Ltd has established strategic business partnerships, trying to satisfy to a maximum extent all your needs when using our product portfolio.

Data security which you vested in us, is very important for us. It is of great significance for our business success and for our public image. Therefore we protect your personal data by applying all appropriate technical and organizational means at our disposal in order to avoid unauthorized access, unauthorized or fraudulent use, loss or untimely deletion of information.

We only collect and process personal data in strict compliance with the requirements of the local and European law. We are aware that the processing of your data is connected to a specific reason and cannot be performed unrestrictedly.

The present Privacy Policy aims at explaining how and why we process your personal data.

How and why do we use your personal data?

For performance of a contract or within the context of pre-contractual relations

We process your identification data and other personal data in order to provide the products and services which you have ordered and which you use from us, as well as to perform contractual and pre-contractual liabilities and to benefit from the rights under the contracts concluded with you.

Processing is performed for the purpose of:

identity verification of the client or its attorney through all commercial channels;
management and completion of your requests for products or services, performance of product and service agreements, including ensuring of signing of concluded contracts and other documents;
drawing up proposals for contracts;
processing by data processor upon conclusion of a contract, assignment, reporting, acceptance, payment;
issuing and sending bills/invoices for the products and/or services provided by us;
ensuring comprehensive service, as well as collection of the amounts due for the products and services used;
ensuring the compatibility of the data from your bills/invoices with the initial purpose of their collection and for the purpose of drawing up an overview of our products and services;
any technical cooperation for the support of the services rendered;
notification in relation to the products and services provided by us, sending out various notices, notifications about problems, errors or responses to your requests, complaints or suggestions;
analysis of the client»s history and outlining a customer profile for the purpose of determining the right offer for you;
ascertainment and/or prevention of illegal actions or actions contradicting our terms and conditions for the relevant services;
evaluation and assessment of the efficiency of our adds, as well as offering marketing content adequate to your needs.

For performance of statutory obligations

We process your identification data and other personal data in order to comply with obligations envisaged in a statutory regulation, such as:

performance of obligations in connection with remote sales, sales outside the commercial outlet, as envisaged in the Consumer Protection Act;
provision of information to the Consumer Protection Commission or to third parties, envisaged in the Consumer Protection Act;
provision of information to the Personal Data Protection Commission in connection with obligations envisaged in the regulatory provisions related to personal data protection – Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc.;
obligations envisaged in the Accountancy Act and the Tax and Social Security Procedure Code and other related statutory deeds, in connection with the keeping of correct and lawful accounting records;
provision of information to the court and to third parties in relation to legal proceedings, in compliance with the requirements of the procedural and substantial statutory deeds applicable for the relevant proceedings.
After your consent

In some cases we only process your personal data after obtaining your prior written consent. Your consent constitutes separate grounds for processing of your personal data and the purpose of the processing is indicated therein and is not covered by the purposes listed in this policy. If you give us your consent and until its withdrawal or termiation of any contractual relations with you:

we prepare proposals for products/services of PTS Bulgaria Ltd appropriate for you, by making detailed analyses of your basic personal data;
prepare appropriate proposals for you in relation to products or services offered by company partners by processing your basic personal data.

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

Usage data – summarized data on the usage of services provided by PTS Bulgaria Ltd, including type of service, total number and duration of use.

After your consent we process your personal identification number, full name and permanent address for preparation of contracts.

The provided consent may be withdrawn any time. Consent withdrawal does not reflect the performance of the contractual obligations of PTS Bulgaria Ltd. If you withdraw your consent for personal data processing for some or all methods described herein above, PTS Bulgaria Ltd shall not use your personal data and information for the above specified purposes. Consent withdrawal does not affect the lawfulness of processing based on the given consent prior to its withdrawal.

We offer a wide range of products and services. When you give us your consent for data processing, this consent relates to all products and services that you use.

In order to withdraw your given consent you only need to use our contact data.

With a view to our legitimate interest

We use your identification data for preparation of subscription bills with our legitimate interest, in order to make a basic analysis of your data for the purpose of adjucting our services to your individual needs and to offer you new services to your satisfaction.

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

Preparation and storage of statistical information and references in an aggregated form in order to develop and improve our products and services and improve the service offered to our clients.

Anonymized data processing

We process your traffic data for statistical purposes, which means for analyses in which the results are only summarized and therefore the data are anonymous – for example in order to present participation in training sessions or proficiency testings. Identification of a particular person on the basis of this information is impossible.

What data do we process:

identification data:

full name, personal identification number or foreigner»s personal number, permanent address, identity document, including data on the type, number, date, place and issuing authority of the identity document submitted;

other data:

information about the type and contents of the contractual relations as well as any other information pertaining to the contractual relations, including:
- audio records of training sessions aiming to improve the service;
- video records of training sessions aiming to improve the service;
- e-mail, letters, information about your requests for elimination of problems, complaints, applications, grievance;
- other feedback from you;
- personal contact data – contact address, telephone number and contact information (e-mail, telephone number), sex, age group;
- other information, such as:
  - customer number, code or another identifier created by PTS Bulgaria Ltd for identification of a user/participant.

Your rights in connection with your data processing

Right to be informed

You have the right to request from us information whether and to what extent we process your personal data.

Right to correction:

In case we process incomplete or erraneous data, you have the right at any time to request their correction and completion.

Right to deletion:

You may request deletion of the personal data related to you in case we process such data with no legal grounds. Please note that there may be reasons preventing the immediate deletion due to statutory requirements for preservation of such data.

Right to restrict processing:

You can request restriction of the personal data that are being processed, if:

you dispute the authenticity of the data for the period in which we need to check their credibility; or
data processing has no legal grounds but instead of deletion, you request their restricted processing; or
we do not need such data any longer (for the specified purpose) but you need them for the establishment, exercising or defense under legal claims; or
you have filed an objection against data processing, pending verification of the legal grounds of the data controller.

Right to data portability:

You can request from us to provide the personal data which you have vested in us in an organized, ordered, structured generally accepted electronic form, if:

we process your data under the contract and on the basis of the declaration of consent which may be withdrawn or on a contractual obligation;
the processing is performed automatically

Right to objection

In case we process data for purposes/objectives of public inerest or in the course of exercising official powers vested in us, or we have indicated that the processed data for our legitimate interest, you can object the data processing.

Right to complain:

Should you believe that we violate the applicable statutory provisions, we kindly ask you to contact us for clarification of the issue. Of course you have the right to submit a complaint to the Personal Data Protection Commission. You can also submit a complaint to another regultory body within the EU.

Righ to object the processing for the purposes of direct marketing due to our legitimate interest

When we process personal data because of our legitimate interest, for the purposes of direct marketing you are entitled at any time to file an objection against the personal data processing related to you for this type of marketing, which also includes profiling, as long as it is connected with direct marketing.

Competent bodies for personal data protection:

In order to file a complaint, you have the right to approach the Personal Data Protection Commission (2, Prof. Tsvetan Lazarov Blvd., Sofia 1592, Tel. +3592/91-53-518, E-Mail: hkzld@cpdp.bg) within 6 months as of becoming aware of the violation, however not more than two years of its occurrence. In case of refusal of access to personal data or correction thereof, you have the right to approach the commission for assistance in the exercising of your rights.

Please notify the other users if they use services purchased by you (for example personnel or family members) regarding the processing and delivery of your data.

The applications for exercising such rights are submitted in person or by an experessly authorized attorney through a notarized power of attorney. In case the application is submitted by mail or in writing without verification of an identification document by a representative of PTS Bulgaria Ltd, the application should bear notarization of the signature. The application may also be sent electronically, signed by a qualified electronic signature. The application should contain: a) name, address, personal identification number or other identification data of the natural person; b) description of the request; c) preferred form of communication and actions pursuant to Art. 15-22 of Regulation (EU) 2016/679; d) signature, date of submission of the application and mailing address; e) upon submission of an application by an authorized person, the application shall be accompanied by the relevant power of attorney.

Notice of data security breach

Where there is a probability for the data security breach to cause a high risk for your rights and freedoms, PTS Bulgaria Ltd shall send you a due notice of security breach.

We do not send notifications if any of the below conditions is met:

we have taken appropriate technical and organizational measures for protection of your personal data affected by such a security breach;
we have consequently taken measures guaranteeing that there are no further possibilities of materialization of the high risk for your rights and freedoms;
individual notification requires efforts which are not proportionate. In such case we make a public announcement or adopt a similar measure in order to be equally and effectively informed.

Updates and modifications of the policy

For the purpose of application of the most advanced protective measures and compliance with the effective legislation, we shall regularly update the present Privacy Policy. If the changes we make are significant, we can publish a notice for the changes made in our Internet webpages. We invite you to review the current version of this Privacy Policy on a regular basis in order to be constantly informed about the way we protect your personal data collected by us.

This Privacy Policy was last updated on 11 May 2021.