TAWAL (hereinafter “TAWAL,” “we,” “our,” or “us”) has established this Privacy Notice for the handling of personal data of (business) customers, coverage requesters, landlords, and job seekers (hereinafter referred to as “customer,” “customers,” “you,” “Your,” or “yours”). It is our objective to provide excellent service to all our customers. This Privacy Notice is formulated in accordance with the General Data Protection Regulation (GDPR) applicable in the European Union. This notice explains your rights under these privacy laws and helps you understand the nature of personal data we collect from you and how your personal data will be treated by TAWAL. By using our different services and products, you acknowledge your acceptance of this Privacy Notice.

This Privacy Notice applies to all sectors and business units in TAWAL. All TAWAL staff, contractors, and vendors working either on a permanent or temporary basis are obliged to follow the outlined standards.

  1. Definitions:

    1. GDPR: General Data Protection Regulation (EU) 2016/679.
    2. Personal Data: Any information relating to an identified or identifiable natural person.
    3. Privacy Notice: This privacy notice including its terms and conditions stipulated herein.
    4. Privacy Laws: GDPR and any other applicable data protection laws.
    5. TAWAL: United Towers Bulgaria EOOD, a Bulgarian entity incorporated under the law of Bulgaria, having its registered office at 1784 Sofia, Mladost District, 86 Tsarigradsko Shose Blvd, Bulgaria. Any use of the words “We,” “Our,” or “Us” means and shall refer to TAWAL.
    6. Utilization: Your use of the Website, whether for requesting a certain service or product, submitting a complaint, applying for a job, and/or any other use may be applicable on the Website from time to time, for which the Personal Data is required.
    7. Website: This Privacy Notice governs the Personal Data that will be collected via TAWAL’s website.
  2. Why We Collect and Use Your Personal Data

    The Personal Data we gather about you, as well as the methods employed to collect it, may differ based on your utilization of the products and services you use and apply for, your usage patterns of these products and services, and your interactions with us. This applies even if you are not a customer of TAWAL, encompassing Personal Data acquired from third parties with explicit permission to share it with us.

  3. The Legal Basis for Processing Your Personal Data Could Be:

    We will only process your Personal Data if we have a legal basis to do so. This includes:

    • Contractual: To fulfill our services obligations to you.
    • Explicit Consent: For activities such as information, sales, and marketing. Additionally, explicit consent will be collected when processing involves sensitive data, credit data, and when decisions are made solely based on automated processing of Personal Data.
    • Legal Obligation: To comply with government requirements including but not limited to, national security and protection of public health.
    • Legitimate Interest: Pursued by us or third parties.
  4. The Purposes of this Data Collection Include but Are Not Limited To:

    • Enabling us to develop, enhance, market, and/or deliver products and services to you.
    • Enabling and supporting our operations and systems to ensure continuity and quality of our services and provide accurate billing and enable us to process payments for products and services.
    • Understanding your needs and your eligibility for products and services and recommend products and services that would be relevant to you.
    • Communicating new products and services launched.
    • Resolving any queries or complaints you may have and allowing us to provide you with a personalized experience across all our channels.
    • Provide reports to third parties and/or our enterprise clients where such reports do not contain any of your Personal Data in accordance with applicable Privacy Laws.
    • For credit checks in certain scenarios e.g., when contracting for any new products or services, and we sometimes supplement the Personal Data we collect about you with data from other sources to assess the accuracy of the Personal Data that we hold e.g., data from governmental entities.
    • For fraud prevention where we process your Personal Data to protect against and detect fraud, to protect and detect misuse or damage to our networks, to recover debts, or to trace those who owe us money resulting from the use of our services.
    • In addition, TAWAL may work with other entities to ensure quality of service is provided. If your Personal Data is disclosed to these entities, it shall be restricted to the purposes specified in this Privacy Notice for which you have provided explicit consent.
  5. What Personal Data We Collect and Use

    The main types of Personal Data we collect from you and use include:

    • Personal Data required when registering with our services (such as name, e-mail address, address, phone number, date of birth, nationality, gender).
    • Personal Data required for you to use our services or Website (such as cookies and usage data).
    • Personal Data exchanged during communications with you (such as customer support requests and feedback from you).
    • Device data for product recommendations and solving technical complaints (such as Device ID).
    • Personal Data required to improve operational services and resolve network-related complaints (such as customer location data).
  6. How We Collect Your Personal Data

    We may collect Personal Data in different ways, including:

    1. Product and Services: When you register, use, or sign a contract to become engaged with us whether as a customer, landlord, or any other type of engagement to use one of our products or services.
    2. Direct Interactions: When you complete a form and send it to us via our Website, by email, post, or via a phone call to our call center. This includes any Personal Data you provide to us when making an inquiry or taking part in a promotion.
    3. Social Media Interactions: Any posts and interactions you have directly with us on social media channels.
    4. Browsing: Personal Data about how you are using our website, including the date and time of your visit, the type of internet browser you use, and how you were referred to our website.
    5. Website Surveys: Our online Website surveys enable us to gather specific Personal Data regarding issues such as your feedback on the look and feel of our Website. Additionally, we may also request Personal Data on several elements of our services to the Website’s visitors. Your feedback is vital, appreciated, and enables us to enhance the quality of services we provide. The provision of your name and other details is optional.
  7. How Long We Store Your Personal Data

    Your Personal Data is retained only for the duration necessary to fulfill its intended purposes and meet legal, regulatory, accounting, or reporting obligations. TAWAL ensures Personal Data deletion after this necessary duration and avoids collecting third-party Personal Data unless required by law.

  8. Data Protection and Disclosure

    1. We take the protection of your Personal Data very seriously and will employ appropriate organizational and technical data protection and security measures and procedures, including internal audit, external audit, training of staff and contractors on privacy, and reporting to our audit and data governance steering committees and regulatory authorities, to safeguard your Personal Data from any unauthorized disclosure or processing.
    2. TAWAL always maintains the privacy and confidentiality of all Personal Data collected. Such Personal Data may only be disclosed or shared when approved and required by law, or when we believe that such action is necessary or desirable to provide products and services, or technical support, and according to the “Why We Collect and Use Your Personal Data” section.
    3. TAWAL does not rent, sell, exchange, or transfer your Personal Data to third parties outside of TAWAL or partner companies without your permission unless it is collected without identifiers on an aggregated basis for analytical purposes, studies, reports with adherence to applicable privacy laws. Additionally, we may share your Personal Data with trusted third parties who assist in operating our Website, conducting our business, or providing services to you, under the condition that they commit to maintaining the confidentiality of your Personal Data.
    4. TAWAL may transfer Personal Data outside the European Union only if appropriate safeguards are in place, such as standard contractual clauses or binding corporate rules, to ensure the protection of your Personal Data.
    5. TAWAL will not disclose your Personal Data without your consent except under the following circumstances where the entity requesting disclosure is a public entity and in which case the Personal Data will be shared in strict accordance with the controls and procedures set out in the applicable privacy laws:
      • For security purposes.
      • To implement another law.
      • To meet judicial requirements.
      • To protect public health or safety.
      • To protect the life or health of a particular individual(s).
  9. Social Media

    We may engage with you on social media platforms to provide information, respond to inquiries, and promote our products and services. Please note that any information you post or disclose on our social media pages may be visible to the public, whereby you will be responsible to exercise and maintain the necessary caution when sharing any Personal Data through our page on a social media platform.

  10. Your Rights

    As an owner of Personal Data registered on our Website, you are entitled to the following rights in accordance with applicable privacy laws, unless there are legal, regulatory, or judicial decisions preventing, restricting, or conditioning these rights:

    1. The right to be informed: You have the right to know and be informed about our contact details, the specific reasons for collecting your Personal Data, the methods used for Personal Data collection, and whether the collected Personal Data will be shared with third parties or not.
    2. The right to access: You have the right to access your Personal Data held by TAWAL.
    3. The right to obtain a copy: You have the right to obtain a copy of your Personal Data held by TAWAL.
    4. The right to request rectification: You can request the correction or update of any incomplete, inaccurate, or outdated Personal Data that TAWAL has collected from you.
    5. The right to request erasure: You have the right to request the deletion of your Personal Data collected by TAWAL. This can be due to various reasons, such as you are withdrawing your consent for your Personal Data collection or that the Personal Data is no longer serving its initial purpose. However, please note that TAWAL may retain such Personal Data in accordance with applicable privacy laws.
    6. The right to object and withdraw your consent: You have the right to revoke your consent, block marketing calls, or stop receiving promotional messages by emailing dpo@tawal.eu.

    TAWAL is committed to ensuring that you are properly informed about your rights and has established dedicated channels for you to exercise them effectively. Moreover, TAWAL aims to address all requests or complaints within 30 days and maintain records of all interactions.

    If you believe that any of your Personal Data is inaccurate or incomplete and needs to be corrected or completed, or you wish to exercise any of the rights stated above, or have any privacy-related inquiries, please do not hesitate to contact us using the provided contact details below in the section: “Contact Us With Your Questions and Comments”.

  11. Privacy Information Specific to TAWAL Website Usage of Cookies

    TAWAL uses cookies and similar technologies to improve your experience on the Website.

    A cookie is a small file that is stored on your computer’s hard drive. Its functions include:

    • Keeping you signed in to TAWAL’s website.
    • Being essential for the website to operate correctly.
    • Helping TAWAL understand how you interact with TAWAL’s Website.
  12. Changes to this Privacy Notice

    To ensure that we continue to offer the best possible experience and the highest level of protection to you, we reserve the right to update this Privacy Notice as and when necessary and appropriate, including but not limited to compliance with the requirements of applicable privacy laws. Any update to this Privacy Notice will be available here. We therefore recommend you check it periodically.

  13. Contact Us with Your Questions and Comments

    In case of any questions, comments, or complaints, or if you wish to exercise your rights regarding the processing of Personal Data, you can reach us via email at dpo@tawal.eu.

    You also have the right to lodge a complaint with the supervisory authority in your country of residence.

    Contact details for authorities in EU countries can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

  14. Links to Other Websites

    Our Website may contain links to third-party sites, which may be subject to separate privacy policies. These sites are not under our control, and we are not responsible for their own privacy policies.

  15. Updates to this privacy notice and GDPR Policy

    1. Regular Reviews and Revisions We continuously review and update our GDPR policy to keep pace with changes in laws, operational shifts, and technological developments. This ensures that TAWAL consistently leads in data protection within the telecommunications sector.
    2. Communication of Changes We regularly refresh our GDPR policy to mirror any changes in our operations, legal requirements, or advancements in data protection technology. We will notify stakeholders of significant updates either through our website or directly, maintaining transparency and ensuring ongoing compliance.
    3. Purpose of Updates The updates to this policy are designed to keep our GDPR practices not only compliant but also aligned with the best practices and specific legal requirements of the telecommunications industry, thereby enhancing the protection of user rights and data security.

    This version was last updated on 15 October 2024.