Уведомление за поверителност относно записи на входящи и изходящи телефонни разговори
"Please read this document!
At the beginning of each phone call, our employee will inform you that the call will be recorded, indicating that more information about the recording conditions can be found in this document.
We know that providing detailed information during the call is practically impossible, as it can be confusing and hinder the conversation. At the same time, however, we are legally obligated to provide you with this information. Therefore, in order to balance your right to receive the necessary information and our obligation to provide it, we have created this comprehensive Privacy Notice regarding the recording of incoming and outgoing phone calls, which complies with the available best practices in the field of data protection.
If you have any questions, please feel free to contact our data protection officer at the email:
[email protected]
Information in accordance with Articles 13/14 of the General Data Protection Regulation.
Data about the administrator:
“EOS Matrix” Ltd, UIC: 131001375
Address: 6 Racho Petkov Kazandzhiyata Str., postal code 1766 Sofia, Bulgaria.
Purposes of processing and legal basis
Phone calls made to and from our Customer Service Contact Center (“Call Center”) are recorded for the purposes of:
Internal monitoring for compliance with legal and ethical frameworks in communication with customers.
Investigating reports, complaints, and grievances from customers.
A limited number of these recordings, after anonymization, are used for the purposes of:
Training and improving the qualifications of employees, as well as enhancing service to enable more effective communication with customers.
The data being processed and the activities themselves are based on:
Legitimate interests of the customers of “EOS Matrix” Ltd to receive quality service that complies with legislation and ethical standards.
Under the data protection legislation, this is a legal basis specified in Article 6, paragraph 1, letter e) of the GDPR.
Legitimate interests of the employees of “EOS Matrix” Ltd, in case it is necessary to prove a certain circumstance in response to a complaint from a customer/another person or from a supervisory authority (as long as the complaint was made within the retention period of the recordings) or alternatively, if there are doubts about unprofessional or unethical behavior of an employee, as a result of which an internal investigation is conducted.
Under the data protection legislation, this is a legal basis specified in Article 6, paragraph 1, letter e) of the GDPR.
Regulatory requirements for “EOS Matrix” Ltd to ensure compliance with applicable legislative requirements, including those for the sector, as well as the legitimate interests of “EOS Matrix” Ltd to provide quality service to its customers, to train and improve the qualifications of its employees, and to protect the security of the company, its customers, and employees.
Under the data protection legislation, this is a legal basis specified in Article 6, paragraph 1, letter e) of the GDPR.
You have the right to object to such a recording by notifying our telephone operator. In this case, the call will be marked for "immediate deletion." You can also send your request to the above-mentioned email of the data protection officer, namely:
[email protected].
In case you raise an objection, an additional review of the content of the call will be conducted, specifically whether it violates the legitimate interests of the company or a third party.
If such a violation is not established, the call will be irreversibly deleted within seven days. We will explicitly inform you of the results and the action taken.
In case a dispute arises regarding the call, it will be retained until the completion of the investigation procedure itself.
We would like to inform you that the recordings are used only for the purposes mentioned above, and the recordings are made using technical means and systems without functionalities for automated processing of your personal data (including biometric data), and there is also no possibility for you to be profiled or to be subject to automated decision-making.
The recordings are stored in an internal system of “EOS Matrix” Ltd for a minimum period, as specified below.
Categories of data and sources of data
The personal data we collect during incoming/outgoing phone calls to and from our Call Center is provided to us directly by you.
Your phone number has been obtained from your previous creditor, another obligated party regarding the credit, another designated contact person from your side, or if you have contacted us from the specified phone number or during communication with you, if you have explicitly provided a specific phone number.
If a contact number for you appears in public registers (e.g., in the Commercial Register and the Register of Non-Governmental Organizations with the Registry Agency), we may use this phone number to contact you.
“EOS Matrix” Ltd follows a strict information security policy for its clients during phone calls, which excludes the provision of information about you and your obligation to third parties when those parties have no connection to the specific obligation.
When recording phone calls, the following categories of personal data are processed:
Recording of the voice of the person initiating the phone communication and of the employee of “EOS Matrix” Ltd who receives or makes the call.
Information identifying the employee of “EOS Matrix” Ltd who receives or makes the call (name, position).
Information identifying the person who receives or makes the call.
Other data that the person voluntarily decides to share during the phone call.
Depending on the purpose of the incoming/outgoing call to and from our Call Center, it may also be possible to collect other information regarding your obligation that we have purchased (e.g., providing information about the amount of the obligation, options for entering into an agreement for installment of the obligation, or clarifying reasons for delay or lack of payments, etc.).
As a rule, only information about you that is necessary for us to manage and collect the respective obligation is processed. This includes the collection and processing of personal data about you that are not classified as special categories of personal data (“sensitive data”), revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or membership in trade unions, as well as the processing of genetic data, biometric data solely for the purposes of identifying a natural person, data about health status, or data about the sexual life or sexual orientation of a person. Therefore, we emphasize that if during the phone call you decide to share such sensitive data, “EOS Matrix” Ltd will not be able to take them into account and process them without your explicit written consent. The call operator will explain the requirements of the Vulnerable Customers Management Policy, under which sensitive data about you may be collected, as well as the conditions under which these sensitive data may be collected, namely by filling out a special declaration.
Recipients
Only duly authorized employees of “EOS Matrix” Ltd have access to phone recordings for the purposes mentioned above.
In certain cases, during the investigation of incoming reports and complaints, phone recordings may also be disclosed to competent law enforcement authorities in fulfillment of our legal obligation to assist them during the investigation.
The personal data contained in recordings of phone calls made with/from our Call Center is not transferred to a third country outside the European Union or to an international organization.
Retention period
Recordings of incoming/outgoing phone calls will be stored through our recording system for up to 6 months. If necessary to extend the period for the purpose of protection against legal claims (e.g., in case of a dispute with or complaint from a customer), we may retain specific recordings until the respective case is resolved.
Rights of data subjects
You have the right to object by sending an email as mentioned above or by informing our operator.
Beyond the right to object to the recording being made, “EOS Matrix” Ltd will consider and respond to any other inquiry and/or request for exercising rights under Articles 15 – 22 of the GDPR, including your right to information, right of access, right to rectification, right to deletion, right to restriction of processing, within a period not exceeding 1 month.
In accordance with Article 77 of the GDPR, you also have the right to lodge a complaint with the Commission for Personal Data Protection, Republic of Bulgaria, which is our supervisory authority.
This policy was updated on December 21, 2023."