Privacy Policy towards Business Partners, Representatives and Employees, and Subcontractor Personnel

Your personal data are very important to us and we make all reasonable efforts to undertake the necessary measures to keep your privacy. We invite you to carefully read this Privacy Notice, which outlines the basis on which Smartcom processes your personal data as well as your rights in respect of such personal data.

Smartcom - Bulgaria AD is a trade company registered with the Commercial Register at the Registry Agency under UIC 130985811, with registered office and address: 1421 Sofia, 20 Lozenets str., website: (“Smartcom”).

Smartcom is the data controller in respect of the personal data it collects and holds about you in connection with its relationship with existing and prospective customers, suppliers, subcontractors, consultants, external auditors, industrial organizations and other persons with whom Smartcom maintains or is considering to create a business relationship.

The data subject is a representative or employee of an existing or prospective business partner or a subcontractor personnel.

1.  Personal data we process

The categories of personal data we may collect and process about you include:

·  contact information, such as full name, work place, work position, work address, work telephone and fax number and work email address;

·  identity card data of the subcontractor personnel – number, date of issue, validity and issuing authority;

·  video image, time and duration of the visit from the video surveillance of secure zones, when you visit our office;

·  further information processed in connection with the relationship between Smartcom and a business partner/ subcontractor or voluntarily provided by a business partner/ subcontractor contact information.

Smartcom does not collect or otherwise process special categories of personal data of business partner representatives or employees and of the subcontractor personnel revealing racial or ethnical origin, political views, religious or philosophical convictions, trade union membership, data concerning health or sexual orientation.

2.  Purposes of personal data processing

In the context of the business relationship with Smartcom, Smartcom may processes personal data for the following purposes:

·  communicating with business partners about products and services of Smartcom or business partners, e.g. by responding to inquiries or requests;

·  managing the relationship with business partners, e.g. by performing orders of products or services, processing payments, performing billing and accounting activities, arranging shipments and deliveries, facilitating repairs or replacements of equipment and providing support services;

·  granting subcontractor personnel access to Smartcom customers’ premises;

·  protecting Smartcom critical assets; 

·  solving disputes, enforcing contractual agreements and/or exercising or defending legal claims;

·  complying with applicable laws and regulations, including cooperating with relevant government bodies and regulators.

If we need to also use your personal data for other purposes we will provide specific notice at the time of collection and request your consent where necessary.

3.  The basis for personal data processing

Smartcom will not process your personal data if we do not have a proper justification foreseen in the law for that purpose.

In particular:

·  we process your personal data, such as contact information and identity card data of subcontractors personnel and further information processed in connection with the relationship between Smartcom and a business partner/ subcontractor or voluntarily provided by a business partner/ subcontractor contact information, on the ground of conclusion and/or performance under commercial contract with our existing or prospective business partners and subcontractors.

·  we process your personal data such as video image, time and duration of the visit on the ground of our legitimate interest to secure critical assets of Smartcom;

·  we process your personal data such as your name on the ground of our legal obligations to comply with the respective regulatory and accountancy legislation whenever we issue invoices, perform billing activities and transactions;

·  we may process your personal data related to solving disputes, enforcing contractual agreements and/or to establish, exercise or defend legal claims on the ground of our legitimate interest to protect our legal rights.

4.  Storage. Access to and sharing of your personal data

Your personal data will be stored on paper or in electronic format.

In the course of our activities and for the purposes listed in this Privacy Notice, your data can be accessed by or transferred to the following categories of recipients on a „need to know“ basis:

·  Smartcom’s employees to the extent and volume necessary for the performance of their labour functions and duties;

·  consultants, service providers incl. IT systems providers and other related business entities; 

·  law enforcement authorities, regulators or attorneys, if necessary, to comply with the law or for the establishment, exercise or defense of legal claims.

The above parties are contractually obliged to protect the confidentiality and security of your personal data in compliance with applicable law.

5.  Data security

Smartcom maintains appropriate technical and organizational measures against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unlawful access to personal data.

6.  Data retention 

Unless indicated otherwise, Smartcom will retain personal data for as long as is necessary for the purpose for which they were collected or otherwise processed (including as required by applicable law or for the exercise or defense of legal claims).

In particular:

·  we will retain your personal data necessary for the conclusion and performance of а contract until the contract is effective and afterwards, until the legal prescription periods for protection of our rights expire;

·  we will retain your personal data necessary to comply with the regulatory and accountancy requirements for the period defined in the applicable legislation  and afterwards until the terms for tax inspection expire;

·  we will retain your personal data related to the video surveillance for not more than 2 months after the record is done. 

7.  Your rights

You have the following rights with respect to the processing of your personal data:

·  right of access - to request access and obtain a copy of your data;

·  right of rectification - to request Smartcom to change incorrect or incomplete data about you;

·  right of erasure ("right to be forgotten”) – to request Smartcom to delete your data when they are no longer necessary for the purposes of processing; please note that we may reject or restrict the request in some circumstances depending on the information we process and the lawful reason to keep the data;

·  right to restrict processing – to request that we do not use the personal data you have provided (e.g. if you believe them to be inaccurate or they are no longer needed);

·  right to object – to object to certain processing of your personal data unless we have overriding compelling grounds to continue processing;

·  right to data portability - to request Smartcom to provide you with a copy of your personal data in a structured commonly used and machine-readable format as well as to request us to transmit your personal data directly to another controller, when this is technically feasible;

·  right to withdraw consent - to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

The rights listed here are not absolute and there may be an exceptions in cases provided by law. We will ensure to provide you with explanations regarding such exceptions when you contact us.

If you are willing to exercise any of the rights specified above, you may contact Smartcom as set out below.

8.  Contact information

If you are willing to exercise your rights under Art. 7 above or if you have any questions with respect to this document, please contact Smartcom as follows:

• address: BIC IZOT, Building 1, Floor 3, Office 317, 133 Tzarigradsko Chaussee Blvd., 1784 Sofia 

• phone: +359 (2) 9650650

• e-mail:

If you think that Smartcom processes your personal data in breach of the applicable data protection legislation, you have the right to submit a complaint to the Personal Data Protection Commission: 1592 Sofia, 2, Tsvetan Lazarov Blvd.;;

9.  Updates to our Privacy Notice

We may need to update our Privacy Notice periodically to provide you with the most accurate information about processing of your data and ensuring compliance with the applicable law. Any update of this document will be posted on our website. If we materially change the way in which we process your personal data, for example the purpose of why we use your personal data, the identity of the Controller or your rights, you will be notified via email or SMS.