Privacy policy

Plumtex EOOD, hereinafter the “Provider” or “PlumTex”, respects your right to privacy and actively protects it. The Provider publishes this privacy statement to inform you about our policy and practice regarding personal data and the choices you have about how your personal information is collected and used online.

PRIVACY POLICY

We take the privacy of personal data seriously. With this policy we would like to introduce you to how personal data is processed at Plumtex.

By visiting our website, you accept our Privacy Policy, which means that you agree to our terms. If this is not the case and you do not agree with our Privacy Policy, we recommend that you do not interact with us in any way.

Please read the information below in detail about how and why we collect and process personal data.

PLUMTEX PRIVACY NOTICE

Plumtex EOOD, Bulgaria, UIC 204520744, hereinafter “Plumtex”.

Plumtex is responsible for processing personal data. Plumtex processes personal data within the framework of the applicable legislation.

Terms used

The terms used in this Privacy Notice have the meaning given to them in Article 4 of the GDPR and should be understood in that sense.

A data subject is a natural person who can be identified;
A controller is the legal entity which, alone or jointly with others, determines the purposes and means of processing personal data;
A processor is the legal entity which processes personal data on behalf of a controller;
Personal data is any data that directly or indirectly relates to a natural person (data subject).
Processing of personal data is any operation on personal data, including collection, storage, alteration, disclosure by transmission or erasure.
Traffic data is data generated while networks are used. An example of traffic data: when a natural person uses a mobile network, information is generated about who sends and receives the message or phone call, the start and end time of the communication and the location of the mobile phone. When traffic data is linked to you as a natural person and you can be identified by it, directly or indirectly, it is considered personal data. Traffic data can, for example, be used for invoicing.
Anonymised data is data from which all identifying elements have been removed, which makes it impossible to link the data to a specific data subject.

Privacy notice and processing of personal data at Plumtex

When you use products and services offered by Plumtex, we process the following main types of personal data:

If you have a contract with us for one or more of our services, we will use your personal data as a Customer or Supplier.
If you do not have a contract with us and contact us through one of our communication channels – for example, by visiting our website – we will use your data as a potential Customer or Supplier.
Personal data of end users that our Customers provide to us while using our services is called end-user data.

The nature of the processing depends on the type of data you provide.

Plumtex offers many services and technical solutions to its Customers. This is a general description of how Plumtex processes data; the specific processing may be broader or narrower depending on the technical solution used by the Plumtex Customer.

Plumtex as a controller

Processing of personal data by Plumtex as a controller is defined by and set out in this Privacy Notice, as well as in the relevant data processing agreements concluded between Plumtex and its Customers/Suppliers, where applicable, or is based on the legitimate interests of Plumtex.

Contact details of Suppliers, Customers, investors and their employees:

Plumtex may receive your data as contact details when, for example, you contact our sales department or our investor relations team, or when you register on our website or for our online services. In connection with the above, we may ask you to provide personal information. This may include your name, address/postcode/city/country, phone number and/or e-mail address.

Furthermore, we may collect and process additional personal data or information that you provide to us when you contact us with specific requests and/or when you apply for vacancies, ask about job adverts or send occasional requests.

Website visitors: www.notify.bg and www.plumtex.com

Plumtex may collect information when you visit the website by placing and using cookies. This includes, among other things, your IP address, the type and version of your browser, which pages of the site you visit and the duration and frequency of your visits. We use cookies for this purpose. You can read more about cookies below.

Employees of Plumtex:

Employees in all positions at Plumtex are familiar with the goals of the GDPR and how to observe and apply the applicable rules.

Users of SMS and e-mail services (end users):

Plumtex provides technical connectivity for routing SMS, e-mail and/or so-called “over-the-top” (OTT) messages sent by our Customers (as controllers) to end users (data subjects) through a communication channel chosen by the Customer.

Combining (enriching) personal data with data from other sources (for example, publicly available sources of economic and demographic data) before this personal data is anonymised and segmented for marketing or reporting analysis. Please note that neither Plumtex nor a Plumtex Customer will use combined (enriched) data until it has been anonymised.

Examples of personal data processing activities in which Plumtex acts as a controller:

Notifying Customers/Suppliers and their representatives and employees about:

Changes to the general terms, payment methods/financial and other terms or the Privacy Policy,
Changes directly related to the provision of services by Plumtex, such as service updates, technical terms and documentation,
Payment status for services provided (invoicing and payment flows), including discount codes,

Answering enquiries:

about services, terms or this Privacy Notice;
about the operation of Plumtex services;
about providing information related to the quality of the service.

Other processing activities:

managing the user account and the consents of the end user;
getting in touch or providing information that may be of interest to the website visitor after they have filled in the relevant form on our website or otherwise expressed their wish for this (so-called “opt-in”);
receiving information about the use of our website, as described below in the section on cookies;
initiating the sending and routing of SMS, OTT or e-mail messages by our Customer (as a controller) to the end user (data subject);
Customer satisfaction surveys;
Managing members/subscribers and making offers to members/subscribers;
Improving and evaluating the website and the services;
Handling requests to exercise rights;
Complying with the applicable legislation.

Types of personal data

As a controller, Plumtex may process the following types of personal data:

Basic personal data, such as name, contact details such as e-mail address, phone number, etc.;
Traffic data: personal data processed when providing electronic communication services or billing for these services;
Data relating to the content of the communication, such as e-mails, voice messages, SMS/MMS, data about the browser used, etc.;
Information about visits to the website through placing and using cookies.

Your personal data will not be used for automated individual decision-making, including profiling.

The legal grounds for processing by Plumtex are the following:

Performance of contractual obligations to provide a service to the end user, for example: managing a user account or subscriptions; notifying end users about changes to the terms of the services; answering enquiries related to the services, the terms of their provision or this Privacy Notice;
For the purposes of the legitimate interests of Plumtex (where these interests are not overridden by the interests or fundamental rights and freedoms of the data subject), for example: improving the services or user interaction; protecting or exercising legal and other claims; preventing harm to Plumtex or a third party, and preventing threatening actions that could cause such harm to Plumtex or a third party or endanger the security of the personal data of the end users of the services;
Consent, for example for the marketing and advertising of Plumtex services;
Compliance with a legal obligation that applies to Plumtex, for example continued storage of personal data to meet legal accounting requirements.

Plumtex as a processor:

Processing of personal data on behalf of the Customer is governed by a data processing agreement, under which Plumtex has undertaken to process the personal data only to provide the services to the Customer, according to the Customer’s instructions and the data processing agreement. When the service contract ends or on the Customer’s instruction, we will delete or return the processed personal data, unless otherwise provided by the relevant legislation.

Examples of personal data processing activities in which Plumtex acts as a processor:

Sharing tools that help you send or route SMS and OTT messages (such as features for building/entering a database of numbers or providing short numbers);
Creating statistics and reports on message sending;
Monitoring traffic for message delivery and system stability;
Managing the consents received from data subjects;
Storing and managing information relating to data subjects on behalf of controllers;
Providing the services offered.

Depending on the service and how Customers use it, Plumtex as a processor may process the following types of personal data:

Basic personal data, such as name, contact details such as e-mail address, phone number, etc.;
Special categories of personal data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or health;
Traffic data: personal data processed when providing electronic communication services or billing for these services;
Data relating to the services provided by our Customers, such as transaction history or events related to the messages;
Data relating to the content of the communication, such as e-mails, voice messages, SMS/MMS, data about the browser used, etc.;

Supervisory authority: Commission for Personal Data Protection – Sofia 1000, 15 Ivan Geshov Str., tel. +359 2 940 2046; fax +359 2 940 3640; e-mail: kzld@government.bg, kzld@cpdp.bg;

Storage of personal data

Personal data is stored until the relevant contract ends or until the end users request its deletion. Please note that complying with certain legal obligations may require continued storage of personal data after the contract ends. Examples of such obligations are legal requirements in accounting, counter-terrorism and anti-money laundering, etc. Continued storage of personal data is also possible when necessary for the legitimate interests of Plumtex, including but not limited to protecting or exercising legal and other claims.

Information under the Electronic Commerce Act and the Consumer Protection Act:

Name of the Provider: “Plumtex” EOOD;

Registered office and management address: 39 Hristo Botev Str., Troyan 5600, Bulgaria;

UIC: 204520744;

Who do we share data with?

Plumtex may disclose personal data to its partners for the purposes of the services provided.

Relations with these partners are governed by a data processing agreement.

Disclosure of personal data to the relevant official authorities is possible when and to the extent required by the applicable legislation.

Your personal data (as website visitors) may be transferred to third countries (USA) based on your explicit consent – this concerns the information about cookies.

Plumtex meets the stated GDPR requirements by the steps below:

How do we use cookies?

Plumtex uses cookies and similar technologies on its websites. Cookies help us determine which parts of our websites are popular, which pages are visited and for how long. The data is used for developing and analysing services, as well as for marketing targeting of partner services.

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device to identify your browser or device. Cookies cannot damage your computer or the files on it. Cookies only let a site or service know whether your computer/device has visited that site or service before. Cookies can be used to obtain information about how a site or service is used. They also help you navigate between pages more efficiently, save your preferences and generally improve your interaction with the website.

We use cookies to

Enable the use of certain services, for example authenticating cookies used to log in to the site and keep login sessions;
Adapt the content of the website to the individual preferences of the user by “remembering” the settings chosen by the user and personalising the user interface, for example chosen language and regional settings;
Create statistics that help us understand how website users use them, which allows the website to be better tailored to the needs of users;
Provide marketing content to website visitors according to their interests.

This website uses cookies. They are used to personalise content and ads, to provide social media features and to analyse visits. We share information about the use of the website with our social media, advertising and analytics partners, who may combine it with other information that you have provided to them or that they have collected from your use of their services. By continuing to use our website, you agree to our cookies.

Cookies are small text files that websites can use to make the user interaction more efficient.

Under the applicable legislation, we may store cookies on your device to the extent they are necessary for the normal operation of the website.

The law states that we may store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your consent.

“Plumtex” EOOD has the right, but not the express obligation, to use and/or install cookies to track activity and provide relevant information.