In order that we can perform the contracts entered into with users we need to process their personal data. Otherwise, it will be impossible for us to fulfill out contractual commitments to users.
We process users’ data to ensure that goods and/or services provided correspond to what is stipulated for them in users’ contracts.
In order that we can perform our obligations under a contract signed with a user we need to process his/her personal data. It is precisely by virtue of them that Telenor identifies the user as the principal under the contract, the conditions of the respective subscription plan, etc.
• If we do not know that a user has the right to use services via a 4G network as per the contract signed the user will be deprived of the opportunity to use such technology;
• If we do not know that a user has the right to use unlimited minutes to all national mobile and landline networks in Bulgaria, (s)he may be charged consumption as per the Telenor’s standard price conditions;
• If we do not know that a user wants to receive paper invoices such invoices might not be sent to him/her;
• To send an invoice issued to the respective user we need to process data regarding his/her address.
We process users’ data so that we can provide them with the agreed services.
In order that we can provide services to users as well as to properly charge them for such services (including in order that we can prove the authenticity of the prepared bills) we process their basic data, data regarding the contracts as well as traffic data.
In contrast to landline services which are provided only to a specific address, mobile services are accessible at any place where Telenor’s network has coverage. In order that we can provide you with the services your mobile device connects to a specific base station of the network that services the respective location and thus we also process data regarding the approximate location of users.
• It is impossible for us to direct the call to the proper addressee without processing data regarding the mobile number dialed by a user;
• It is impossible for us to charge a call in compliance with the provisions stipulated in the contract with the respective user without processing data regarding the type and duration of the call;
• It is impossible for us to provide a detailed printout, if such is requested by the user, without processing the traffic data of the user.
We process users’ data to maintain our mobile network and information systems
In order that we can prevent, discover, localize and make good faults and software errors in the network and our information systems, including when we receive complaints from users, we need to process their personal data and traffic data.
We process users’ data for the purposes of payments related to interconnection
In order that users of different operators and networks can establish a connection between each other operators and networks must be interconnected. To that end the two operators enter into a contract under which their networks are connected. By virtue of that contract the operators owe to each other payments for the calls made by their subscribers.
For example, if a Telenor user calls a subscriber of another mobile operator in Bulgaria Telenor will owe certain sum to the respective mobile operator as the amount of that sum is determined based on the duration of the phone call.
We process users’ data for the purposes of payments in relation to services provided in roaming.
In order that Telenor users can use services in roaming (i.e. outside the territory of the Republic of Bulgaria) Telenor must settle its relations with the operators whose mobile networks serve the users. To that end Telenor enters into agreements with the respective mobile operators. By virtue of such agreements Telenor owes a payment whenever a Telenor user uses services provided via the network of another mobile operator.
For example, if a user located on the territory of the Hellenic Republic makes a phone call Telenor will owe a payment to the respective Greek mobile operator whose amount is determined on the basis of the type and duration of the phone call.
We process users’ data for the purposes of charging and preparation of bills
We process basic data, data regarding the contracts as well as traffic data so that we can prepare the subscriber bills, carry out internal control of their accuracy and reliability and issue invoices for the services provided.
We process users’ data so that we can administer the process of servicing their payments
Whenever a user makes a payment under a contract with Telenor as well as whenever a user wants to defer or reschedule his/her liabilities to Telenor, we process his/her basic data, data regarding the contracts, data regarding the liabilities and data regarding the payments.
We process users’ data for the purposes of settlements with our partners
In order that Telenor users can enter into contracts, register prepaid cards, pay bills (including refill prepaid cards), submit requests and/or be served at an outlet of the trade network of our partners (e.g. trade representatives, franchisees, distributors, providers of payment services, etc.) Telenor enters into agreements with them. By virtue of such agreements Telenor owes sums for the determination of which data regarding the users need to be processed.
• It will be impossible for us to determine and pay the remuneration due to a franchisee of ours without processing the information that a user has entered into a contract for mobile services at a trade outlet of such a franchisee;
• It will be impossible for us to determine and pay the remuneration due to a trade representative of ours without processing the information that a user has paid his/her bill at an outlet of such trade representative.
We process users’ data to notify them of the occurrence of certain circumstances in relation to our contracts.
In order that we can perform our obligations to inform the users of the occurrence or the forthcoming occurrence of certain facts and circumstances that have impact on the provision of our products and/or services we process the following personal data: basic data; data regarding the contracts; data regarding the liabilities; data regarding the payments; traffic data; data regarding communication with users, etc.
• Notification of the exhaustion of the applicable credit limit or reaching certain amount thereof in pursuance of the stipulations of Telenor’s General Terms and Conditions;
• Notification of an invoice issued, including its value and maturity date;
• Notification upon temporary discontinuation of the access to the services in pursuance of the stipulations of Telenor’s General Terms and Conditions;
• Prior notice upon a scheduled routine maintenance checks, repair works and/or modifications of the network in pursuance of the stipulations of Telenor’s General Terms and Conditions;
• Notification when Telenor establishes user’s predominant presence and consumption in EU/EEA which may result in the application of a markup according to Regulation 531/2012 pursuance of the stipulations of Telenor’s General Terms and Conditions;
• Notification that a number dialed by the user, which was turned off or outside coverage, can be dialed;
• Notification of the applicable prices and conditions when the user is in roaming;
• Notification of a successful refill of a prepaid SIM card;
• Notification of a forthcoming expiration of the validity period of the credit for a prepaid SIM card;
• Notification of a payment made by using “Pay with Telenor” service;
• Notification of a forthcoming actions to be taken to collect unpaid cash liabilities out of court, including the use of third parties’ services (credit reporting bureaus, debt collection agencies and others) in accordance with Telenor’s General Terms and Conditions, etc.
We process users’ data so that we can carry out their requests.
In order that we can fulfill the requests of a user in relation to a concluded contract(s) we need to process his/her basic data, the data regarding the respective contract(s) as well as data regarding liabilities and/or payments (if applicable).
• In order that an operation of recharge a prepaid SIM card can be performed we have to process the basic data of the respective user, data regarding the contract as well as data regarding the payment made on the basis of which a recharge is made;
• In order that a user’s request for replacement of a SIM card (e.g. in case of damage or loss) we need to process his/her basic data as well as data regarding the contract;
• In order that users’ requests can be fulfilled (e.g. for activation or deactivation of services in roaming or the mobile internet service, issuance of a duplicate of a contract, an invoice, etc.) we need to process their basic data, the data regarding their contract and other data relevant to the request.
We process users’ data for the purposes of customer care.
We process personal data of our users so that we can provide them with quality and timely customer care, including but not limited to processing of user proposals, applications, requests, inquiries and/or complaints. The type and the volume of personal data we process in such cases depend on the nature and content of the respective proposal, application, request, inquiry and/or complaint.
• In order that a check can be made in case that an inquiry or a complaint has been received from a user as well as in order that a response to it can be prepared, and sent to the user, respectively, his/her basic data, the data regarding his/her contract, other data regarding the inquiry or the complaint made (e.g. traffic data, data regarding the liabilities, data regarding the payments, etc.) as well as the communication data need to be processed.
We process users’ data when number portability from/to Telenor’s network is carried out
In order that we can provide the service of number portability from/to Telenor’s network we need to process the personal data of the respective users.
We process users’ data when out-of-warranty maintenance of goods requested by them is carried out
In order that we can fulfill users’ requests for performance of out-of-warranty repairs of goods we need to process their personal data.
We process users’ data in order to prevent, detect, investigate and discontinue abuses
In order that we can prevent, detect, investigate and hinder wrongful acts, which are contrary to the conditions on the use of our products and/or services or which violate the applicable legislation we process users’ personal and traffic data.
In cases of “atypical conduct” of our users we need to process their data in order to establish whether there is an abuse, a breach of the General Terms and Conditions or the applicable legislation. In case that conduct that threatens or hampers the normal use of the services is established Telenor may restrict the access to the services of the users in question.
We process users’ personal data when necessary in order to exercise our rights under contracts concluded with them
The contracts Telenor enters into with its users give rise to rights for both parties. Both Telenor and the users make enjoy such rights to satisfy their interests. The procedure and conditions on the exercise of such rights are regulated in the contracts themselves and sometimes they arise directly out of the applicable legislation. In order that Telenor can exercise its rights with respect to the users Telenor needs to process certain personal data on them.
Examples of hypothetical cases where Telenor processes personal data in order to exercise rights under contracts concluded with the users:
•In the event that a user terminates early a contract at his/her will Telenor may process his/her personal data in order to charge penalties according to the stipulations of the contract;
•In order that Telenor can make a current credit assessment of the user according to Telenor’s General Terms and Conditions Telenor needs to process his/her personal data so that it can analyze whether the user meets the requirements for the current trade policy;
• In order that Telenor can exercise its right to restrict and discontinue the use of the services by a user when (s)he exceeds the credit limit applicable for him/her according to Telenor’s General Terms and Conditions Telenor needs to process his/her personal and traffic data.
We process users’ data where this is necessary for the collection of unpaid sums under concluded contracts
If a user does not pay the sums owed to Telenor as agreed in the concluded contract Telenor has the right to seek payment out of court or subject to court procedure. To that end the following user’s data must be processed: basic data, data regarding the contracts, data regarding the liabilities and data regarding the payments. If the user contests a charged consumption, Tlenor may also process the relevant traffic data in order to demonstrate the accuracy of the bill.
When performing the procedure of out-of-court collection of liabilities Telenor may make use of the services of third parties (debt collection companies) to whom the aforesaid data may be disclosed. Data regarding personal identification number [EGN] shall be disclosed to such companies only after the user’s consent is obtained.
When carrying out a legal collection of liabilities Telenor may make use of the services of lawyers and/or law firms to whom the aforesaid data may be disclosed, including data regarding personal identification number [EGN].