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Privacy Policy (GDPR)

System Security and Integration Ltd., hereinafter referred to as "SSI", is a company registered in the Commercial Register at the Registry Agency with UIC 204280623, with registered office and address of management: 5 Voden Str., Varna, Bulgaria. 

SSI is a personal data controller within the meaning of the Personal Data Protection Act, registered by the Personal Data Protection Commission (CPDP) with a Certificate № 424586 issued and entered in the public register of personal data controllers.

This Privacy Policy is based on the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement and cancellation of such data of Directive 95/46 / EC ("Regulation (EU) 2016/679").

SSI respects the right to maintain the confidentiality of personal information and data of individuals in connection with the processing of personal data and ensures the protection of their personal data and information for the purposes of processing personal data, recipients or categories of recipients to whom they may be disclosed data, the obligatory or voluntary nature of providing data, as well as the consequences of refusing to provide them, information about the right of access and the right to correct the collected data, according to the requirements of Art. 19 and Art. 20 of the Personal Data Protection Act (PDPA).

All changes and additions to the Privacy Policy will be implemented after the publication of its current content, available on shop.lavender.bg

The privacy policy applies to personal data, to an individual or a representative of a legal entity that uses or wishes to use electronic communications and other services provided by SSI.

Personal data is any information related to the identification of a natural person directly or indirectly, in particular by an identifier such as name, identification number, location data, online identifier or one or more characteristics specific to the physical, physiological, genetic, mental, the mental, economic, cultural or social identity of that individual.

Processing of personal data is any operation or set of operations performed with personal data or a set of personal data by automatic or other means such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure, disseminating or otherwise making the data accessible, arranging or combining, restricting, deleting or destroying.

By providing your personal data, you consent to their processing and storage in accordance with this policy.

Responsibility for your personal data

SSI is a company registered in the Commercial Register with the Registry Agency with UIC 204280623, which collects, processes and stores your personal data under the terms of this Policy.

SSI is a controller of personal data within the meaning of Regulation (EU) 2016/679 and the Personal Data Protection Act.

SSI collects the following categories of personal data:

Personal data for preparation and subsequent execution of a contract or order:

- full name, personal identification number (ЕГН) or personal number of a foreigner, address;

- full name, personal identification number (ЕГН), address and other details of the proxy specified in the document by which you have authorized them to represent you before SSI;

- type and number of identity document, date of issue, validity and issuer;

- telephone number and / or e-mail address for contact or contact person;

- data collected on payment made to SSI - credit or debit card number, bank account and other electronic channels;

- data from your account for access to the self-service customer profile and SSI website - username, history of orders and payments;

- data on the services you use from the SSI portfolio;

- data provided when participating in games, raffles and / or other seasonal or promotional campaigns organized by SSI on its website or through social networks;

Personal data for the purposes of providing the services:

- customer number and service number;

- monthly invoices and detailed reports and amount of liabilities;

- traffic data necessary for the provision of services, for charging, for the formation of subscribers' accounts;

- volume of transferred data;

- location of a service user;

- data necessary for the preparation of the monthly bills;

- value of the used services;

- type of service used;

- total number of units of account accrued for the relevant period of preparation of the periodic accounts;

- method of payment;

- payments made and due;

- information on changes in the use of services;

- restrictions and restoration of services;

- data to be processed to determine the geographical location of the terminal, including when roaming;

- data on the final electronic communications device used, the type of device, the operating system used;

- IP address;

- voice recording of telephone conversations with an operator on 052 600 500, 0896 600 500, 052 70 39 71, 052 612 650 in connection with requests for amendments or additions to the service contract, claim for damages;

- receiving information and assistance in connection with the used service and the provided access device;

- voice recording of telephone conversations, of which we inform you, initiated by an operator from the Customer Service Center regarding services to existing customers and offering services or concluding a distance contract for new customers;

- IP address for using mobile internet by SSI;

- information on the type and content of the contract with SSI, any other information related to its servicing, including records of calls made to and from the contact center, e-mails, letters, complaints and grievances and other feedback submitted by in relation to a terminal electronic device purchased from SSI;

- credit rating data required for certain products offered;

- data about the services you have chosen.

Reasons and purposes for processing your personal data:

In order to fulfill our contractual obligations to you, SSI processes your identification data, traffic data and other personal data in order to ensure the use of the products and services you have requested and use and purchase when concluding or executing orders and the contract for electronic communications and other services as follows:

Customer identification at:

- concluding, changing or terminating a contract for services and goods;

- fulfilment of received requests for information on consumption;

- explanations of the proposed plans;

- explanations of invoices and payment of bills,

- accepting complaints or grievances.

- ordering goods and services

Customer identification is performed:

In all trade and communication channels - SSI store, customer service number 052 600 500, 0896 600 500, 052 70 39 71, online platform (self-service portal), online selling (e-shop), contact telephone operators centres and contact form through the website;

Upon request for change of personal data and provision of information about the used services;

When performing credit assessment through initial and subsequent analysis, credit risk assessment, analysis and forecasting of customer payment history and behavior, verification of data validity, when concluding contracts for electronic communications services, leasing contracts or when purchasing a device;

When preparing and analysing customer history and preparing user profile (volume and type of consumption, payment history when offering a suitable offer for you, if you want to change the used tariff plan, activate roaming, change the maximum consumption limit);

When checking the volume of customer consumption at your request in order to protect customers and SSI from atypical traffic, current account; remaining included consumption, value by invoice.

When clarifying invoices for monthly fees and preparing reports on used and terminated services;

When concluding distance contracts outside the commercial site of an SSI partner, sending a courier consignment including the required set of documents,

When servicing customer complaints, grievances and inquiries;

In case of adjustments of amounts due, if there are grounds for that;

In case of technical assistance for creation of account(s) and recovery of forgotten password for access to the platforms for electronic service of electronic invoices, detailed references;

In case of limitation and restoration of the service in case of damaged or lost / stolen card;

In case of technical support through remote access to the equipment for using the service;

In case of restriction and recovery of services suspended due to non-payment;

When paying bills;

Providing protection and security of the SSI network;

In order to comply with the requirements set out in regulations, SSI processes your data in accordance with the established legal obligations for the following purposes:

Preparation of distance and off-premises contracts of an SSI partner, sending by courier;

Sale of receivables from customers, where information about the debt is provided to the assignee, as well as contracts, monthly invoices, protocols and other accounting documents, if any;

Information on sold obligations under assignment contracts for the purposes of confirming the transfer of receivables;

Providing information about the client and the services used by him inspection by a competent authority;

Accepted consents;

Issuance of invoices, preparation of a detailed report on the consumption of the used services;

Legitimate tax and social security control by the relevant competent authorities;

Providing information to the Communications Regulation Commission, the Commission for Personal Data Protection and the Commission for Consumer Protection, in the performance of the obligations arising from the relevant laws;

Providing information to the court and third parties in proceedings;

Management and storage of traffic data in accordance with the requirements of current legislation;

Certification of age for signing a contract for the use of a service against payment of a monthly fee and for online shopping.

SSI processes the relevant data provided with the explicit written consent of the client for their processing for the following purposes:

Providing external credit agencies for the purpose of determining a credit rating assessing creditworthiness on the basis of credit history to provide for the possibility of deferred payment, using a banking instrument;

When you participate in raffles and games organized on the SSI website, in SSI outlets and / or in social networks, which are held in compliance with the requirements of the Personal Data Protection Act. All participants give their consent to the collection and storage of their personal data for the purposes of raffles and games;

In order to receive and / or provide information or offers for products and services to third parties, and this information is processed lawfully and in good faith, the data will not be provided to third parties without your express consent.

The processing of personal data in these cases is carried out on the basis of written consent for the processing of your personal data, which you have provided to SSI.

Consent is a separate ground for the processing of your personal data, which you have the right to withdraw at any time if the withdrawal does not affect the lawfulness of the processing based on the consent given before its withdrawal. In this regard, you will be informed before giving your consent.

When considering the consent or its withdrawal, it is taken into account whether the fulfillment of the contractual obligations under a contract or the provision of the service under it is made dependent on it. Withdrawal of consent does not affect the fulfillment of SSI's contractual obligations.

SSI also processes your data for the purposes of our legitimate interest as follows:

Profiling of clients for the purposes of direct marketing through automated processing of personal data, expressed in the use of algorithms and methods for evaluation and analysis of some aspects of customer consumption, duration of sessions, services used and preferences in order to:

- loyalty programs such as: proposal to be included in a special group to be able to take advantage of special discounts;

- behavioral advertising - measuring and evaluating the effectiveness of our advertising in order to optimize advertising content to the needs of our customers;

- updating the information published on our website in the most appropriate way in order to facilitate and useful access to this content for SSI customers;

Processing data on the services used, allowing reliable analysis and evaluation of the diversity of our products and services and consumer demand.

A detailed analysis of customer behavior based on various criteria, such as, but not limited to, gender, age, place of residence, could be used to develop new products that to meet the needs of current and future customers could improve their service.

Preparation and storage of information in order to improve its product range of services and to improve customer service;

Third parties with access to the processing of your personal data:

Third parties who process your personal data on behalf of SSI under a contract with SSI:

Transport and courier companies in the performance of our contractual obligations for the delivery of contracts on paper;

SSI Partners who enter into contracts with end customers on behalf and for the account of SSI;

Partners providing end-to-end service support services;

Debt collection agencies on behalf of SSI;

Companies providing services such as a contact center for direct marketing or providing technical assistance;

Banks servicing payments made by you;

Companies providing services for organizing, storing, indexing and destroying archives on paper and / or electronic media;

Consultants offering consulting services in various fields.

Other data controllers to whom SSI provides your personal data, processing your data on their own basis and on their own behalf

Assignees - to whom the receivable is assigned, as a party to assignment agreements, and to whom SSI, in its capacity as assignor, transfers (sells) for your outstanding obligations;

Competent authorities, Bulgarian court or court of another state, various supervisory / regulatory bodies - Consumer Protection Commission, Communications Regulation Commission, bodies with powers for protection of national security and public order;

Credit agencies, which together with SSI determine the purposes and means of processing your personal data during a credit assessment based on an individual approach, in determining the credit rating and in assessing the deferred payment (purchase of lease), which we aim at its maximum satisfaction;  

Processing of anonymized data

For analysis and statistical purposes, SSI processes your traffic data, whereby the received data are summary and in this sense - anonymous, where identification of a specific person is impossible.

The duration of the storage of your personal data depends on the purposes of the processing for which it was collected, and it is stored for as short a time as possible:

The personal data processed at the conclusion of the contract for the provision of services are stored for the term of the contract and until the final settlement of all financial relations between the parties;

Personal data processed during the issuance of accounting / financial documents for the implementation of tax and insurance control, invoices, debit, credit notices, handover protocols, contracts for the provision of services, etc. shall be kept for at least 5 years after the expiration of the limitation period for repayment of the public receivable to which they are related, according to Section III, Art. 12, para. 1 of the Accounting Act, unless the applicable legislation provides for a longer period.

Traffic data processed under the Electronic Communications Act in accordance with the procedures for storing traffic data for national security purposes, which are necessary for the prevention, detection and investigation of serious crimes, are stored by SSI for a period of 6 months.

SSI may store some of your personal data, including traffic data, for a longer period until the expiration of the relevant limitation period in order to protect against any claims of customers in connection with the termination of the service contract, as well as for longer term in case of a legal dispute that has already arisen in connection with an effective court decision.

Voice recording - telephone conversations - 2 years from the conversation.

SSI and what actions you need to undertake to implement them:

As our client and with regard to your personal data, you have the following rights:

The right of access to your data

Access your personal data and information, such as we have included in this Privacy Policy with respect to the data in question;

You may request information from SSI for the purpose of processing your personal data.

The right of adjustment

Request that your inaccurate personal data be corrected when it is inaccurate or incomplete personal data is to be filled in;

The right to delete ("to be forgotten")

Withdraw your consent on which the processing is based and request that your personal data be deleted only in one of the following cases:

(a) personal data are no longer needed for the purposes for which they were collected and processed;

(b) the processing of the data is recognized as unlawful;

Right to limit processing

Request to limit the processing of your personal data in any of the following cases:

(a) the accuracy of the personal data is disputed by you for the period necessary for SSI to verify the accuracy of the data;

(b) the processing is illegal, but you only want to limit the processing of your data instead of deleting it;

(c) SSI no longer needs them for processing purposes, but you want your personal data to be stored, as you will use it to establish, exercise or protect your legal claims;

(d) pending verification, if you object to the processing of your personal data regarding the legal grounds of SSI for this;

The right to data portability

Request the transfer of your personal data that affect you and that you have provided to us, including receiving it from SSI in a structured, widely used and machine-readable format and which you have the right to transfer to another controller of personal data. Your right to portability applies to personal data for which the following conditions are met:

(a) the processing is based on your explicit consent or contractual obligation;

(b) the processing is carried out in an automated manner.

The right to object

To object to SSI at any time and on your personal grounds in view of the specific situation, against the processing of personal data concerning you for which there are compelling legal grounds, for the performance of a task in the public interest or in the exercise of official authority, which have been provided to us, or for the establishment and protection of our legitimate interest.

In the event of an objection to the processing of your personal data, SSI will respond within a period of not more than one month whether it finds it justified and whether it will terminate it.

the processing of relevant personal data for these purposes.

If you object to the processing of your personal data for direct marketing purposes, including profiling for that purpose, SSI will discontinue processing for that purpose.

The right to withdraw your consent

Withdraw your consent to the processing of your personal data at any time, when their processing is based on your consent. You can state your wish through the partner network and the channels for communication with SSI.

The right to send a complaint to the Commission for Personal Data Protection

Send a complaint to the Data Protection Commission at any time if you believe that your rights in relation to the processing of your personal data have been violated.

You can submit an explicit written application to SSI or let us know about your wish by calling 052 600 500, 0896 600 500, 052 70 39 71, 052 612 650.

Cookies

In order to increase efficiency, improve the convenience of work and make the site as interesting as possible for each visitor, the electronic platform (SSI website) uses a widely used technology called "cookies".

What are cookies?

Cookies are small pieces of data for temporarily storing information about a user's actions, preferences or other activity when visiting a website, which are sent to your browser from a web server and stored on your device so that the site can recognize your computer.

Cookies may not harm your files or increase the risk of viruses on your computer, but they can help make your website easier to use, as it saves users the need to enter their preferences every time they visit or switch from one site to another. page to another.

Each cookie is unique to your browser and contains anonymous information that includes the name of the domain from which it comes.

Cookies allow the website to function smoothly, monitor for irregularities and identify opportunities to optimize the ways in which it provides information and communicates with users.

We use the following types of cookies depending on their degree of need:

System cookies

System cookies are strictly necessary, designed to secure the connection, without which the operation of the site is impossible or is at high risk.

The purpose of system cookies designed for connection security is:

  • To recognize the user within the specific session, to participate in navigating the website and saving the completed information during registration and when going between different steps;
  • To control the security of the connection and protection from unwanted external interference;
  • Ensure that the information that the user enters is only visible to him

System cookies are stored temporarily and disappear after closing the browser session or are kept for a limited time in order to ensure smooth operation of the site.

System cookies, as well as other types of cookies on the site, do not store entered personal data.

Permanent cookies for functionality

Functionality cookies include cookies for device recognition and compliance with individual user preferences regarding language and others.

This type of cookie can be stored for a longer time on the device, it can be used in more than one browser session.

Third-party cookies for efficiency, analysis and advertising

Analytics cookies are intended to collect statistical information on the basis of which general conclusions and recommendations can be made for the effectiveness of the site in view of the goals of users, as well as in view of marketing and advertising goals.

They anonymously measure the number of users per page, the most visited pages, the time spent on the page, the way users navigate the website and the difficulties they may experience or errors that occur.

Disable cookies

As a user, you can choose whether or not to accept cookies, set your browser to notify you, delete cookies stored on your device, and disable the use of cookies in the future.

Please note that blocking cookies will affect the way the website works and may prevent some of our site from functioning properly.


All changes to the Privacy and Privacy Policy will be published on our website.

Visits to our site represent your agreement to SSI's Privacy and Privacy Policy and updates.

This policy was last updated on May 25, 2018.

You can exercise your rights by submitting a written application (in person or through an explicitly authorized person upon issuance of a notarized power of attorney) to SSI. The application may also be submitted electronically in accordance with the Electronic Document and Electronic Signature Act.

The application must contain at least the following information:

  • name, address and other data for identification of the respective natural person;
  • description of the request;
  • preferred form of information provision;
  • signature, date of submission of the application and address for correspondence.

SSI is obliged to rule within 14 days of receipt of the request, respectively within 30 days, when more time is needed to collect the requested data, in view of possible difficulties.

Our management address is: Bulgaria, Varna 9000, 5 Voden Str.

For all questions related to the processing of your personal data, you can also contact the Data Protection Officer at SSI at the following contact details: email: belova@ssi.bg; phone 052 600 500, 0896 600 500.