The protection and confidentiality of your personal data are of particular importance to us. This notice gives you detailed information about the processing of the personal data we collect in relation to the activities we perform and the protection of your personal data by Call Cell BG Ltd.

This notice aims to inform you what personal data about you we collect and use, the reasons why we use and share such data, how long we store the data for and how you can exercise your rights.

This Personal Data Protection Policy applies to your personal data when you use our contact call centre, visit the website www.callcell.bg or use our services through the call centre and this website, and does not apply to other websites or services, which we do not own or control.

The personal data are processed by Call Cell BG Ltd. in line with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), the Personal Data Protection Act and the other applicable acts in relation to personal data protection.

Call Cell BG Ltd. is a single-member limited liability company registered at the Commercial Register and the Register of Non-Profit Legal Entities at the Registry Agency, Unified Identification Code 203929407, registered office and business address: Sofia 1766, Vitosha Region, 5 Panorama Sofia Street, floor 3.

Call Cell BG Ltd. acts in the capacity of a personal data controller in accordance with the applicable personal data protection legislation with respect to the personal data of the users of our website and in providing the services in relation to our core activities. Our core activities are related to providing comprehensive telecommunication (“call centre”) services and telemarketing, including but not limited to distance sales, telemarketing and electronic (“call centre”) services.

In certain cases, Call Cell BG Ltd. is in the role of a personal data processor and, in such cases, Call Cell BG Ltd. has concluded respective agreements with our customers – personal data controllers – who have assigned it to us to process personal data and we abide by these agreements. In such a case, the data subjects should refer to the confidentiality policies of those business customers from whom their data originate.

If you have any questions about this Personal Data Protection Policy or your personal data, please get in touch with us.

Contact details:

Call Cell BG Ltd.

Unified Identification Code 203929407

Address: Sofia 1766, Vitosha Region, 5 “Panorama Sofia” Street, floor 3

E-mail: office@callcell.bg

“Controller” means Call Cell BG Ltd., Unified Identification Code 203929407.

“Personal data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, psychological, mental, economic, cultural or social identity.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

“Applicable law” means the law of the European Union and of the Republic of Bulgaria, which is relevant to personal data protection, including but not limited to: GDPR, Personal Data Protection Act and others.

“Regulation (EU) 2016/679 means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as “GDPR”.

“Special categories of personal data” means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

“Consent of the data subject” means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to the data subject.

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

We collect and process your personal data on the grounds provided for in the applicable law, to the extent necessary in the course of our activities as well as to achieve a high standard for our products and services. We respect the right of privacy and make constant efforts to ensure that the data we process are brought down to the minimum and are afforded maximum protection. Still, for you to use our services we need to process certain personal data. By using any of our services and/or registering a profile, you accept and confirm that you have read and understood this Personal Data Protection Policy as well as our Cookie Policy.

In the cases when the information is not collected to comply with a statutory obligation, perform a contract to which you are a party or take steps at your request prior to entering into a contract, in relation to a legitimate interest of Call Cell BG Ltd. or to protect your vital interests, you may be asked to give your consent to the provision and processing of your personal data. In the event of no consent, it may be impossible for you to obtain some of the services, including receiving notifications about upcoming events and special terms, or the communication with you may be hampered or slowed down.

Depending on the purposes (as defined below) and your role with respect to Call Cell BG Ltd. (customer, potential customer, visitor, employee, successful applicant, unsuccessful applicant and others), you provide to us and, respectively, Call Cell BG Ltd. processes the following personal data in a different extent and scope in view of the specific case:

1. Contact Details Category – physical contact address, e-mail, (cell) telephone number, business contact details;

2. Physical Identity Category – name, father’s name, family name, personal number, physical contact address, e-mail, (cell) telephone number, audio (audio recording);

3. Social Identity Category – profession, education, professional qualification, address of performing activities (if applicable);

4. Website Use Information Category – when, from which IP address and how a user uses the website; technical information about the devices a user uses to access the website; language and other settings; cookies which may identify your browser; user sessions registration on the website, including information about clicks on specific elements and loading pages;

5. Financial Data Category – bank details; remuneration; tax information; distress; credit card details;

6. Remuneration Processing Category – remuneration; amounts to pay and deduct; beneficiaries; dependants; details about receivables; distress; social security information; tax information; family identity; annual leave; sick leave;

7. Employees Category – Contact Details, Physical Identity, Social Identity, Financial Data, Remuneration Processing, labour contracts; training documents; disciplinary documents; family identity; appraisals and assessments; benefits;

8. Applicants Category – name, father’s name, family name; physical contact address, e-mail, (cell) telephone number; curriculum vitae, criminal records (when required for a specific position); previous employment;

9. Other data – other information which you may provide to us voluntarily by using our contact call centre or through accessing and/or using our website, including applications, fill-in forms and others, or through accessing and/or using our official profiles in social media – LinkedIn, Facebook, Instagram, and others.

We do not collect personal data, which reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning your sex life or sexual orientation.

The personal data we collect from you will be used solely for the purposes for which it is stated that the data are collected and/or in accordance with the requirements of the applicable law.

Call Cell BG Ltd. uses the personal data you have provided in the following ways:

1. To provide services to customers – to establish, maintain and service trade relations, to conclude contracts with customers and perform the contracts concluded to which you are a party – the legal basis for processing here is the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract – Article 6 (1) (b) GDPR;

2. To respond to a question, query, request, notification or others about products, services, cooperation, activities of Call Cell BG Ltd. – the legal basis for processing here is the user’s consent – Article 6 (1) (a) GDPR;

3. To implement the recruitment and hiring process – if you apply for a position under a labour and/or civil contract – the legal basis for processing here depends on the stage of the recruitment and hiring process: applicant’s consent – Article 6 (1) (a) GDPR; respectively, the processing is necessary to perform a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract – Article 6 (1) (b) GDPR; compliance with a legal obligation to which Call Cell BG Ltd. is subject – Article 6 (1) (c) GDPR;

4. To register and use our website and/or online application – the legal basis for processing here is the user’s consent – Article 6 (1) (a) GDPR;

5. To improve the functioning of our website – the legal basis for processing here is the user’s consent – Article 6 (1) (a) GDPR;

6. To review complaints – the legal basis for processing here is the legitimate interest of Call Cell BG Ltd. – Article 6 (1) (f) GDPR;

7. To ensure security and safety – the legal basis for processing here is the legitimate interest of Call Cell BG Ltd. – Article 6 (1) (f) GDPR;

8. For direct marketing – the legal basis for processing here is the user’s consent – Article 6 (1) (a) GDPR;

9. To implement the administration of our activities, including reporting and analyses at Call Cell BG Ltd. – the legal basis for processing here is the legitimate interest of Call Cell BG Ltd. – Article 6 (1) (f) GDPR.

Telephone calls to and from representatives of services, which include personal data may be recorded in order to ensure quality and/or performance of a contractual or legitimate obligation and Call Cell BG Ltd. informs you about this in advance.

If Call Cell BG Ltd. intends to use and perform additional processing of your personal data for purposes other than the one they have been collected for initially or to which you have consented at a later stage, Call Cell BG Ltd. will inform you about this and will offer you the option to choose whether you consent that your personal data be used for purposes other than the purpose they have been collected for initially or to which you have consented at a later stage.

Call Cell BG Ltd. does not use automated-decision making processes, including profiling, within the meaning of GDPR.

If the processing of personal data is based on your consent, you may withdraw your consent for the processing of personal data at any time by writing to us in a way which is convenient to you: via a letter at the following address: Business Centre XS Tower, 5 “Panorama Sofia” Street, city of Sofia 1766, by e-mail at:

info@callcell.bg or via submitting a request on site. Your personal data will be erased from the systems of Call Cell BG Ltd. within one month of receipt of your request to withdraw your consent. The withdrawal of consent does not affect the legality of processing based on consent provided before its withdrawal. Consent is voluntary but you should keep in mind that it is necessary and if there is no consent on your part in the cases listed above, Call Cell BG Ltd. will not be able to provide the activities and services related to the consent.

By using the website, you agree to receive the marketing materials, which are an integral part of it. An integral part of the website is, for example, the ad banners through which Call Cell BG Ltd. may promote its services and products or other advertising content. You have the option to reject these marketing messages at any time. When you withdraw your consent, Call Cell BG Ltd. will not be able to send you marketing messages and give you offers, proposals, products, services, invitations to events. The withdrawal of your consent will not affect the legality of processing based on consent provided before its withdrawal.

Call Cell BG Ltd. collects personal data both from you and third parties who have provided information related to you, including but not limited to when you access and use our services and website, you register, submit an order, fill in a request, fill in a feedback form, publish feedback, subscribe for our publications or enter information such as a comment or other on our website. We also collect personal data through communication via e-mail or post/courier service at our physical address.

We have taken a wide range of technical and organisational measures to protect your personal data against loss or other forms of unauthorised processing. The personal data are accessible only to those persons who need to have access to them to perform their work in relation to the provision of our services. Call Cell BG Ltd. protects personal data against risks such as loss or theft, unauthorised access, disclosure, copying, use, change or destruction through appropriate security measures. Call Cell BG Ltd. protects the data regardless of the form in which they are stored.

If you have questions about the security of your personal data, you can get in touch with us by e-mail at: office@callcell.bg

We do not transmit your personal data to third countries and we do not transfer them outside the EU or the EEA.

We process and store your personal data for a certain period of time determined by:

• Periods required for compliance with the Bulgarian and European law;

• Another period in relation to our operational requirements in view of the protection of our legitimate rights and interests.

Call Cell BG Ltd. will not store your data longer than necessary for the purpose for which we have processed your data.

Any personal data with respect to which there is no longer a basis to be processed are destroyed or anonymised in accordance with the procedure after the coming into being of this event.

Pursuant to the personal data protection legislation, you have the following rights in relation to your personal data:

Access: The right to receive confirmation whether personal data related to you are being processed and, if so, to obtain access to your personal data, including information about the source of the data, the purposes of processing and their provision to third parties as well as to obtain a copy of the personal data.

Rectification: When you believe that your personal data are inaccurate or incomplete, you may ask us to rectify such inaccurate personal data related to you, to complement incomplete personal data related to you, taking into account the purposes of processing.

Erasure: You may request the erasure of your personal data when the grounds for this are in place to the extent permitted by law.

Restriction: You may request the restriction of processing of your personal data to the extent permitted by law and in the cases provided for by the applicable law.

Objection: You may object against the processing of your personal data on grounds related to your specific situation. You have the absolute right to object against the processing of your personal data for the purposes of direct marketing which includes profiling related to any such direct marketing.

Consent withdrawal: When you have given your consent to the processing of your personal data, you have the right to withdraw it at any time and any such withdrawal will be in effect with respect to the processing of data going forward.

Data transferability: You may request that data collected from you through consent or based on a contract to be provided in a structured, commonly used or machine-readable format to the extent they have been processed automatically.

You may exercise your rights by submitting a request in writing or a request signed in person or via an electronic signature at the following address: Sofia 1766, Vitosha Region, 5 “Panorama Sofia” Street, floor 3, or e-mail: office@callcell.bg You will receive a response to your request within 30 days unless your request is excessive. In the latter case, we may extend the term to process the request by up to two months. Call Cell BG Ltd. will inform you of any such extension within one month of receiving the request and will indicate the reasons for the delay.

You will not pay a fee for access to your personal data or for exercising any of your other rights. Still, we may impose a reasonable fee if your request is obviously unreasonable, repetitive or excessive.

As a security measure, we may need to request from you specific information to help us confirm your identity and guarantee your rights.

Right to complain before a regulatory authority: You also have the right to submit a complaint to the Personal Data Protection Commission.

Contact details of the Personal Data Protection Commission

Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd

Telephone: 02/91-53-518

E-mail: kzld@cpdp.bg

Website: www.cpdp.bg

We would appreciate it if you get in touch with us first in the event of a complaint so that we can have the opportunity to try and help you.

Our website is not intended for persons under 18 years of age. If you are under 18 years of age, you may use the website only with the consent of a parent or a guardian. If a person under 18 years of age has provided their personal data without the consent of their parents and/or guardians, the latter should inform Call Cell BG Ltd. immediately about it. The website bears no liability if a person under 18 years of age has registered concealing this fact.

If this Personal Data Protection Policy does not answer your questions or you need further information or you have a query, you can get in touch with us directly at the following address: Sofia 1766, Vitosha Region, 5 “Panorama Sofia” Street, floor 3, e-mail: office@callcell.bg

You should review this Personal Data Protection Policy periodically as Call Cell BG Ltd. reserves the right to amend it in whole or in part by posting a new version on our website.

This Policy aims to inform you how our website uses the so called “cookies”.

Cookies are small bits of information (small text files) that the browser stores on your computer or mobile device when you visit our website and that make it possible to remember the flow of information between the website and the browser. Cookies enable the server to collect information from the browser so that you do not need to re-enter it when you return to the website or go from one page to another. Cookies do not relate to an individual but to a combination of a device and a web browser. Cookies perform a number of functions, which impact the seamless surfing of websites. The cookie files usually contain the domain name a user comes from, the “cookie lifespan” and a value (usually in the form of a randomly generated number). Cookies do not require personal information to be able to be work and most often they do not identify the identity of internet users.

Our website uses cookies to improve the quality of the offered services. The data, provided by the user or collected automatically, are used for the following purposes:

• Cookies for functionality and website productivity – accurate website functioning, configuration, safety and reliability; ensuring normal and quality access to the website services with all of their functionalities; monitoring the session status; information about the type of devices accessing the website (e.g. smart phone, tablet, computer), operating system (e.g. Android, iOS), web browser, browser language settings etc.; eliminating problems, administration of the website, pages and our system;

• Cookies for website visitor analytics – check for availability of scripts, software applications and settings of the user’s end device necessary for the normal access and use of the website services, and informing about the lack of such; adjusting the information displayed to the user’s preferences; remembering the user’s preferences, which may be used in displaying the accurately adjusted editorial content;

• Cookies for statistical and analytical purposes – analysis, statistics, search and website audit; trend analysis, most popular website pages, number of page views, number of clicks, number of content shares, number of page and content likes.

It is not strictly necessary to activate these cookies for the main functions of the website but it will ensure better user experience in the browser and our website.

We use the Analytics service, which collects statistics about the use of the website. Cookies are used to this end. To opt out of Google Analytics cookies, open this link: https://tools.google.com/dlpage/gaoptout.

All contemporary browsers allow you to change the cookie settings. You can usually find these settings in the Options or Preferences menu of your browser. You can control and/or delete cookies as you wish. You can delete all cookies already stored on your device and you can also set most browsers to block them. The use of our website in Private view also blocks the storing of cookies. However, if you do this, you may need to set certain parameters manually every time you visit the website and it may also be possible for certain services and functions not to work properly or fully.

You can easily accept or reject the use of cookies on this website by clicking on one of the following links:

• I accept cookies

• I reject cookies (except for the one remembering this choice)

• I reject cookies (*) (In this case, you will see our cookies banner every time you visit our website)

When you use our website, the following data are collected automatically: IP address, domain name, browser type, operating system type.

If you have any questions about this Cookies Policy, please get in touch with us at e-mail: office@callcell.bg

This Cookies Policy has been adopted and is effective as of 2020 .

Call Cell BG EOOD reserves the right to amend this Cookies Policy by publishing a new version on the website. If you disagree with any changes made, you should stop using the website.