PRIVACY AND PERSONAL DATA PROTECTION POLICY AT Diana Net OOD

(„Privacy Policy“)

“ Diana Net“ Ltd. respects the privacy of its customers and guarantees the maximum protection of their personal data processed during and in connection with the provision of electronic communications services, including those offered online through the specialized DKTV and DKTV Mobile platforms , distributed through Google Play and the App Store.

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 natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“ Regulation (EU) 2016/679” ).

All amendments and additions to the Privacy Policy will be applied after publishing its current content, available through our website: https://dnet.bg

The Privacy Policy is applicable to your personal data if you are an individual or a representative of a legal entity who uses or wishes to use prepaid and/or subscription electronic communications services provided by Diana Net OOD, including those offered online through a specialized DKTV platform or DKTV Mobile mobile application.

1. Who processes and is responsible for your personal data?

“ Diana Net“ Ltd. is the commercial company registered in the Commercial Register at the Registry Agency with UIC 128593568, which collects, processes and stores your personal data under the terms of this Policy.

Diana Net OOD is registered in the public register of the Communications Regulatory Commission as an enterprise providing a wide range of electronic communications services.

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

You can contact us at our management address:

Yambol 8600, Zlaten Rog residential area, block 27, floor 15

For all questions related to the processing of your personal data, you can contact Diana Net OOD at the following contact details: email: office@dnet.bg tel. + 359 46/602025 .

2. What data, for what purposes and on what legal basis do we process ?

2. 1. Depending on the specific purposes and grounds, Diana Net OOD processes the following data independently or in combination :

A) Data provided by you, necessary for identification and fulfillment of the contractual obligations of Diana Net OOD and the client:

2. 1. • three names, personal identification number or personal number of a foreigner, address, telephone number and/or e-mail address for contacting you, or a contact person indicated by you;

      • three names, personal identification number, address and other details of your proxy, specified in the document with which you authorized him to represent you before Diana Net OOD;

      • number, date of issue, validity and issuer of an identity document;

      • data collected upon payment made to Diana Net OOD – credit or debit card number, bank account and other banking and payment information collected upon and processed in connection with making the payment by bank transfer, via direct debit or through the online platform and other electronic commerce channels of Diana Net OOD;

      • data from your account to access our online platform – username, order and payment history;

      • data about the services you use from the portfolio of Diana Net OOD;

B) Data prepared and generated by Diana Net OOD in the process of providing the services:

2. 1. • service number, client number, detailed reports on monthly bills/invoices and the amount of the obligations contained therein;

      • traffic data – data necessary for the provision of electronic communications services, for billing, for the formation of subscriber accounts, as well as for proving their authenticity – number of the calling and called end user, device identification number, electronic payment card number, start and end of the call, volume of transmitted data, type of service provided, interconnection points, data on the type of connection or zones – time and territorial, necessary for determining the value of the service; location of a service user;

      • data necessary for preparing subscriber bills, as well as for proving their authenticity – type of service used, total number of units charged for the respective period of preparation of periodic bills; value of services used; information about the payment method chosen by you, payments made and due; information about changes in the use of services, restrictions and refunds of services;

      • location data – data that is processed to determine the geographical location of the end device;

1. • data about the electronic communications terminal device used, the type of device, the operating system used, IP address;

   • voice recording of telephone conversations with an operator at 046/662025;662554 in connection with requests for amendments or additions to the service contract, reporting damage, receiving information and assistance in connection with the service used;

   • voice recording of telephone conversations initiated by our contact center operator when offering services or concluding a contract remotely;

   • video recording during a visit to the offices of Diana Net OOD, prepared with video surveillance equipment for security purposes and with a view to ensuring undisturbed service to employees and visitors at the commercial establishments of Diana Net OOD;

   • IP address when visiting our website, the online service platform, as well as when using internet services;

   • information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including records of calls made to and from our contact centers, e-mails, letters, information about your troubleshooting requests, complaints, requests, grievances and other feedback we receive from you;

   • data in connection with a complaint filed regarding a terminal electronic device purchased from Diana Net OOD;

   • data about your preferred services.

2. 2. Purposes and legal grounds for processing personal data:

A) Data processing which is necessary for the conclusion or performance of the contract for electronic communications services .

Diana Net Ltd. processes your data for the following purposes:

2. 2. • Identification of a client when: concluding, amending and terminating a service contract; fulfilling requests for information on consumption; clarifications about the services used and subscription plans, paying bills and addressing a complaint/grievance. Identification of a client is carried out through all commercial and communication channels – retail outlet, telephone numbers 046/662025; 662554 for customer service, online platform, contact center locations and telephone operators, electronic contact form;

      • Updating your personal data or information about the services used upon your request for correction/change of data/services;

      • Analysis of customer history and preparation of a user profile (volume and type of consumption, payment history) in order to determine a suitable offer for you in the event of a customer’s request to change a tariff plan, change in the maximum consumption limit;

      • Verification of volume and type of customer consumption upon your request/complaint/dispute or in order to protect customers and Diana Net OOD from atypical traffic and shock bills (fraud and abuse by third parties) – current account; remaining included services; invoice value. Clarification of invoices/monthly fees and provision of reports on used and terminated services;

      • Handling and responding to customer complaints/inquiries/appeals ; Adjustments to amounts due if there is a basis for this;

      • Technical assistance for account creation;

      • Technical support and troubleshooting of any technical problems – on site and via remote access to the equipment for using the service. Restoration of services suspended due to non-payment;

      • Payment of bills, rescheduling, deferring amounts due;

      • Checking the technical feasibility of providing a service;

      • Warranty and service of devices;

      • Performing processing by data processors – assignment, reporting, acceptance, payment ;

      • Ensuring protection and security of the Diana Net OOD network;

B) In fulfillment of its legal obligations, Diana Net OOD processes your data for the following purposes:

2. 2. • Providing information about the client and the service used by him upon inquiry/request/inspection of a competent authority.

      • Management of granted consents;

      • Coordination of sketches and designs before implementation of investment projects;

      • Issuing invoices, preparing a detailed report on the consumption of the Services;

      • Carrying out tax and social security control by the relevant competent authorities;

      • Providing information to the Communications Regulation Commission, the Consumer Protection Commission and the Personal Data Protection Commission in connection with the fulfillment of obligations arising from the relevant laws ;

      • Providing information to the court and third parties within the framework of court proceedings;

      • Traffic management in accordance with the requirements of current legislation;

      • For age verification in case it is required by law for online shopping .

C) Diana Net OOD processes the relevant data provided with the client’s explicit written consent for their processing for the following purposes:

2. 2. • To receive and/or provide information/offers for third party products and services, if such information is explicitly requested by you or

If you have consented to receiving such information.

2. 2. • Detailed analysis of consumption data, preferences and

customer behavior (automatic processing in encrypted form) – Diana Net OOD performs the specified analysis using the data anonymously and in a form that does not allow easy identification of the data subject or the same is impossible, in order to develop and improve its product range of services. The analysis of the behavior of certain types of customers, divided by various criteria, such as, but not limited to, gender, age, place of residence, could serve to develop new products/tariff plans that best meet the needs of current and future customers. The specified analysis can also be used to improve customer service by developing contact approaches, restructuring the internal functional units in the company that serve them, and sometimes in order to prevent fraud leading to financial losses for Diana Net OOD.

2. 2. • Preparation and storage of statistical information and reports in aggregated form – Diana Net OOD performs the specified analysis in order to develop and improve its product range of services and to improve customer service;

3. Categories of third parties who access and process your personal data:

   1. Personal data processors who, based on a contract with Diana Net OOD, process your personal data on behalf of Diana Net OOD or have direct/indirect access to your personal data

• Persons carrying out installation and/or maintenance activities at the service provision address ;

• The banks servicing the payments made by you;

3. 2. Other personal data administrators to whom Diana Net OOD provides your personal data, processing your data on its own behalf and on its own behalf

Competent authorities , which by virtue of a regulatory act have the authority to require Diana Net OOD to provide information, including personal data, such as – a Bulgarian court or a court of another country, various supervisory/regulatory authorities – Consumer Protection Commission, Communications Regulation Commission, authorities with powers to protect national security and public order;

3. How long is your personal data stored?

The duration of storage of your personal data depends on the purposes of the processing for which they were collected:

Personal data processed for the purpose of concluding and performing a contract for the provision of a Service and/or the sale of insurance are stored for the duration 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 and credit notes, acceptance and delivery protocols, contracts for the provision of Services, etc. are stored for at least 5 years after the expiration of the limitation period for repayment of the public claim, unless the applicable legislation provides for a longer period.

Traffic data processed under the Electronic Communications Act for the purposes of national security and for the prevention, detection and investigation of serious crimes, as well as for the implementation of search and rescue operations , are stored by Diana Net OOD for a period of 6 months.

Diana Net Ltd. may store some of your personal data, including traffic data, for a longer period until the expiration of the relevant statute of limitations for the purpose of protection against possible claims by customers in connection with the performance/termination of a service contract, as well as for a longer period in the event of an already existing legal dispute in connection with the above until its final resolution with an effective court/arbitration decision.

Voice recording – telephone conversation – 2 years from the date of the conversation.

Picture/video recording/ – up to 30 days from the creation of the recording.

3. What are your rights in relation to the processing of personal data by Diana Net OOD and what actions should you take to exercise them:

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

3. 1. to obtain access to your personal data and information, of the type that we have included in this Privacy Policy with respect to the data in question. You may request from Diana Net OOD information as to whether and for what purposes we process your personal data;

   2. to request that your personal data be corrected when it is inaccurate or should be supplemented in view of the purposes of processing;

   3. to request that your personal data be deleted , only in any of the following cases:

      • they are no longer necessary for the purposes for which they are processed;

      • you have withdrawn your consent/objected to their processing and there is no other basis for their processing;

      • the processing of the data is recognized as unlawful;

      • national or European legislation requires this;

   4. to request that the processing of your personal data be restricted in any of the following cases:

      • if you dispute the accuracy of your personal data for the period necessary for Diana Net OOD to verify the accuracy of the data;

      • unlawful processing has been established, but you only want the processing of your data to be restricted instead of being deleted;

      • you wish your personal data to be stored even though Diana Net OOD no longer needs them for the purposes of the processing, as you will use them for the establishment, exercise or defense of your legal claims;

      • if you object to the processing of your personal data for the period of verification of its validity;

   5. to request the portability of your personal data concerning you which you have provided to us, including receiving them from Diana Net OOD in a structured, commonly used and machine-readable format and transmitting them to another personal data controller. Your right to portability concerns personal data for which the following conditions apply:

a) the processing of the data is based on your explicit consent or a contractual obligation; and

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

3. 6. to object to Diana Net OOD at any time and for your personal reasons in view of the specific situation, to the processing of personal data concerning you, which is based on the necessity to perform a task of public interest or in the exercise of official authority vested in us or for which we have indicated that we process for our legitimate interest.

When the objection is against the processing of your personal data for direct marketing purposes, including profiling for this purpose, Diana Net OOD will cease processing them for the specified purpose.

When the objection is against the processing of your personal data for other purposes, Diana Net OOD will respond to you within a reasonable time, but not longer than one month, whether it finds the objection justified and accordingly whether it will terminate the processing.

the processing of the relevant personal data for these purposes.

3. 7. At any time, you can withdraw your consent to the processing of your personal data when its processing is based on your consent by stating your explicit wish through the sales network and communication channels with Diana Net OOD.

   8. to submit a complaint to the Personal Data Protection Commission if you believe that your rights in relation to the processing of your personal data have been violated.

In case a specific way is not explicitly stated, in order to exercise your rights, you should submit an explicit written application to any of the Diana Net OOD cash desks or make your request by calling 046/662025; 662554.

3. Can you refuse to provide personal data to Diana Net OOD and what are the consequences of this?

In order to conclude a contract with you and to provide you with the services you have requested, we need certain data that is necessary for the conclusion and performance of the relevant contract, as well as for the fulfillment of the regulatory obligations of Diana Net OOD.

Failure to provide the following data prevents Diana Net OOD from concluding a contract with you:

• three names, personal identification number or personal number of a foreigner, address;

• three names, personal identification number, address and other details of your proxy, specified in the document with which you authorized him to represent you before Diana Net OOD;

• number, date of issue, validity and issuer of an identity document;

• data collected upon payment made to Diana Net OOD – credit or debit card number, bank account and other banking and payment information, in connection with making the payment by bank transfer through the online platform and other electronic commerce channels of Diana Net OOD;

• data from your account to access our online platform – username, order and payment history

This policy was last updated on 24.04.2018.

Cookie Policy

“ Cookies“ are short text files that are stored by the browser on your end device when you visit various sites and pages on the Internet.

We use cookies to facilitate the usability of the site and improve its performance. No personal data is stored during this process.

Controlling, disabling or blocking cookies is managed by your browser settings.

All cookies that are used are automatically deleted/erased after a certain period of time.