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How do we process personal data of corporate clients

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We process personal data related to representatives and contact persons of corporate clients when they:
negotiate with us for the purpose of concluding a contract for any product and/or service offered by Yettel, including when the negotiations are conducted within the framework of a tender procedure for the selection of a supplier organized by the relevant corporate clients; or
conduct a public contract award procedure for products and/or services in which Yettel participates under such terms and conditions as provided for by the law;

In such cases, the processing of personal data is necessary in order for us to be able to participate in such negotiations, tender procedure or public contract award procedure, including to exchange information and offers with a view to the future conclusion of a contract.

The conclusion of a valid and binding contract with a corporate client is impossible without processing certain personal data of that corporate client (when the supplier is a natural person) or a representative thereof.

The amount of personal data required to sign a valid contract with a corporate client depends on the type of contract - for example, when a corporate client representative is authorized by virtue of a power of attorney with the signatures subscribed thereto certified by a notary public, we will process not only the names and position of the Attorney, but also his/her personal identification number as well as data from his/her identity document.

In order to be able to fulfill our commitments to corporate clients, and to seek fulfilment of their commitment to us, we must process personal data of the corporate clients (if they are natural persons), representatives and contact persons thereof.

Without such processing it would be impossible to:
provide the products and/or services agreed;
carry on written correspondence or make telephone and/or video conversations and/or joint meetings on the performance of the signed contracts;
organize the acceptance and testing of goods and/or services delivered by us;
issue invoices and seek payments on them;

For the duration of the contracts signed with corporate clients it is possible, on the initiative of Yettel or the corporate clients themselves, to have negotiations on amendment or termination of such contracts. In such cases, in order for us to be able to participate in such negotiations, including to sign additional agreements or terminate any contract, we must process personal data of corporate clients (if they are natural persons), representatives and/or contact persons thereof.

In accordance with the legislation of the Republic of Bulgaria, Yettel has the right to assign to a third party any claims it has towards any corporate client (such as claims arising from issued but outstanding invoices) without obtaining the prior consent of such corporate client. For this purpose, an agreement for the assignment of claims ("cession agreement") is signed with the third party concerned.

Upon the execution of a cession agreement Yettel ceases to be the holder of the relevant claim, which passes to the third party (new creditor). One of Yettel's obligations under the cession agreements is for the new creditor to be handed over all documents establishing the assigned claims. In fulfilling this obligation, Yettel shall provide the new creditor with personal data about the persons whose data is processed by Yettel under this Privacy Policy contained in the relevant documents.

Upon the execution of a cession agreement, the relevant corporate client will be duly informed about it on behalf of Yettel.

Yettel's business operations are subject to control by various government and municipal authorities - Communications Regulation Commission (CRC), Consumer Protection Commission (CPC), Personal Data Protection Commission (PDPC), National Revenue Agency (NRA) and others. In the course of their control, the respective authorities have the power to conduct inspections, as well as to require Yettel to provide any documents and information that are in Yettel‘s possession. Documents and information requested in the course of such inspection may contain personal data of corporate clients (natural persons), representatives and/or contact persons thereof.

For example, when conducting a tax audit, the NRA authorities have the power to require Yettel to provide accounting documents that may also contain personal data of corporate clients (natural persons), representatives and/or contact persons thereof.

The tax and accounting legislation in the Republic of Bulgaria requires Yettel to create and store, for a definite period of time, information, data and documents relevant to the tax and social security control.

In fulfillment of this obligation, the relevant information and documents, which also contain personal data of corporate clients – natural persons, representatives and/or contact persons thereof – are kept by Yettel for such time as stipulated in the relevant laws. Sometimes for a long time (for instance, the tax and social security documents should be kept for eleven years).

Sometimes, in order to exercise our rights or legitimate interests (for example, to seek any invoice payment), we may need to process personal data of certain corporate clients (natural persons), representatives, contact persons and/or employees thereof, to make an out-of-court claim or to bring an action against:
corporate clients; or
third parties from whom we have obtained and/or to whom we have disclosed personal data of the natural persons concerned in accordance with this Privacy Policy.

Accordingly, the corporate clients, the above third parties, and the natural persons themselves, may make an out-of-court claim or bring a case against Yettel. In such cases, we may need to process personal data in order to organize and conduct our defense, and thus prevent any encroachment upon our property and/or reputation.

The type and amount of the personal data processed depends on the nature of the out-of-court claim or the action brought.

It is possible, according to Yettel's internal regulations and policies, upon obtaining the prior consent of the representatives of a corporate client, to process their personal data, including personal identification number, in order to make a credit assessment of the corporate clients represented by them.

Credit assessment is required when signing contracts for mobile and/or fixed services with corporate clients represented by the relevant representatives if the corporate clients wish to receive mobile devices on lease or preferential pricing with a subscription plan.

The consent of the representatives is voluntary. Should a representative refuse to give such consent the corporate client will be able to purchase the desired devices at their full retail price.

A credit assessment is a verification of the creditworthiness of a corporate client. Its purpose is to show us how likely the corporate client is to stop paying his liabilities to Yettel or to fall into a situation where he is not in a position to do so.

In preparing such assessment, previous data related to the corporate client as a customer of Yettel (if Yettel has such) is analyzed.

Upon representative‘s consent, an analysis of previous data for:
other Yettel corporate clients who have been represented by the representative (if Yettel has such data); and
the representative as a consumer of Yettel (if Yettel has such data), is also carried out.

Also, the data for the corporate client and its representative are matched with aggregated statistical information about the Company's good and bad payers.

In the case of a lower credit score, the corporate client may be required to pay a certain initial installment, to provide any other guarantee or security, and in rare cases the corporate client may be offered lower-end devices.