PERSONAL DATA PROTECTION POLICY of the users of the mobile application “Blagoevgrad Traffic” This privacy policy has been adopted in accordance with the requirements of REGULATION (EU) 2016/679 of the European Parliament and of the Council and aims to inform you of your rights in relation to the processing of your personal data. Please,  read this document carefully, as it is designed to explain to you the basic rules that the Municipality of Blagoevgrad (hereinafter referred to as the Company) applies to the collection and processing of your personal data. Please note that the mobile application does not use cookies, nor does it collect other personal data beyond those explicitly stated in this policy. In case the mobile application refers you to other external sites, please consider that the Municipality of Blagoevgrad is not responsible for the information collected by these sites and we kindly invite you to familiarize yourself with the privacy policies of the respective site.


  Name and legal form: Blagoevgrad Municipality, UIC: 000024695, headquarters and address of management: Blagoevgrad, P.O. Box 2700, 1 Georgi Izmirliev Square; MOL: Ilko Stoyanov Stoyanov, 073 86 77 65, email: The company maintains the mobile application “Blagoevgrad Traffic” (hereinafter referred to as the “Application” or the “Mobile Application”) as part of its main activity. The application is designed to provide information about the movement of vehicles and providing the opportunity to purchase products in connection with the use of the service “public transportation of passengers”, carried out within the Municipality of Blagoevgrad. The application provides its users with information about the possibilities of traveling from and to a point of their choice via public transport, incl. Bus and any other type of transport. In addition, the application provides instructions to users on how to quickly, easily and conveniently purchase products offered under the tariff policy of Blagoevgrad Municipality.   Any person can contact us at any of the above addresses, telephone, email, namely: Blagoevgrad Municipality, Information Desk, tel. 073/867703. If you need more information about the collection of your personal data, their storage, use, provision, destruction, access, etc., you can contact the Data Protection Officer.  


What “personal data of individuals” means – these are all data through which a natural person can be identified.   The personal data you provide to the Company when registering in the mobile application “Blagoevgrad Traffic”:

* Name and surname, as a type of personal data, should be understood only your name and surname specified in your identity documents. When registering through the app itself, you specify your name and surname, and when registering through Google and Facebook, the application uses the name and surname  you specify in Google and Facebook. Your actual name and surname may differ from those  indicated by you when registering in the app, Google or Facebook. However, these are not personal data within the meaning of the Bulgarian legislation and the Company does not bear any responsibility for their collection, storage, use, provision, destruction. ** When using the Mobile Application, upon registration in it, as well as when purchasing a ticket or concluding a subscription, you confirm that you are at least 18 years old. Only in this case can you use our services; FOR WHAT PURPOSE DO YOU PROVIDE YOUR PERSONAL DATA: 1. / Conclusion and performance of a contract for the provision of transport service “public transportation of passengers” by using the mobile application “Blagoevgrad Traffic”  The above personal data from your account you provide in order to be able to conclude a contract for transport services “public transportation of passengers” – by purchasing a relevant product according to the tariff policy of the Municipality of Blagoevgrad as well as to individualize you as party to the specific contract and establishing your status as a “passenger” in the means of public transport for passengers. In addition to concluding a contract, your personal data is also collected for the performance of this contract, under which both parties – you, as a User and the Company, as a Transportation Provider, have the obligation to fulfill the conditions provided for within the specified periods. Legal basis for processing – Art. 6, item 1, letter “b” of Regulation 2016/679 of the European Parliament and of the Council; OBLIGATIONS AND CONTRACTS ACT; TSP; CPC; ZMP; 2. / Functioning of the mobile application  After installing the mobile application, the same receives access to the following information from your device: Identifier of your device – so that we can connect the actions you perform in the Application (pressing buttons, etc.) to your device and fulfill your requests; Incoming phone call data – so you can receive calls,  while the application is active; Storage (disk space on the phone) – for installation of the Application; Wi-fi and mobile internet data – to access the Internet from the Application; use of fingerprint hardware – for integration with payment systems. We need access to this data in order for the Application to operate and perform the functions provided therein. Legal basis for processing – Art. 6, item 1, letter “b” of Regulation 2016/679 of the European Parliament and of the Council;   3. /  Access to your location Upon your consent, we also gain access to your location (Location), which is used only for your convenience and convenience – to show you the bus stops closest to you, their schedule and possible tickets for purchase. Access to your location is not mandatory and your consent to receive it can be withdrawn at any time. Withdrawal of consent is done by e-mail to us,  from the settings of your device or by deleting the App. However, please note that if you withdraw your consent to access your location, you will not be able to see the bus stops closest to you and the related information. Legal basis for processing – Art. 6, item 1, letter “a” of Regulation 2016/679 of the European Parliament and of the Council; 4. / Protection of the rights of the Company in cases of non-performance of the contract In addition to the conclusion and performance of a contract,  your personal data is also collected for cases of non-performance of this contract. Thus, for the entire term of the contract, both parties to it – you, as the Buyer and the Company, as the Seller, have the obligation to fulfill the conditions provided for within the specified deadlines,  Any action that deviates from what has been agreed entitles each party to protect its rights accordingly, including through the use of the necessary personal data. Legal basis for processing – Art. 6, item 1, letter “f” of Regulation 2016/679 of the European Parliament and of the Council; 5. / Accounting  and tax purposes Data on the contracts concluded between us are stored and processed in connection with the obligations of all persons to carry out and maintain tax accounting and to pay taxes. In this case, your personal data may be processed entirely for tax purposes. Legal basis for processing – Art. 6, item 1, letter “c” of Regulation 2016/679 of the European Parliament and of the Council; LSA; CITA; PITA; THA; LMA;   PROCESSING INCLUDES A WIDE RANGE OF OPERATIONS WHICH ARE PERFORMED ON PERSONAL DATA, INCLUDING BY MANUAL OR AUTOMATIC MEANS. This includes collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, alignment or combination, restriction, erasure or destruction.   HOW WE STORE YOUR PERSONAL DATA  Your personal data is stored on its own or rented by the enterprise server. Blagoevgrad Municipality has taken all necessary technical and organizational measures to protect your personal data, including through limited access to the server, data separation, security, etc.   Your personal data is stored for a different period, depending on the purpose for which it is collected. 1. / Conclusion, performance of the contract and protection of the rights of the Company in cases of non-performance  of the contract – a period of 4 years from the date on which the full and final performance of the contract by the parties occurs or the termination of the contract on other grounds. The full and final performance of the contract is considered the time or date on which you use the product you purchased at the tariff of the Municipality of Blagoevgrad. In the event that,  that there has been a breach of contract and one of the parties has taken action to protect their rights by judicial, administrative or other procedures – up to 5 years from the date on which the final judicial, administrative or other act was issued. 2. / Data necessary for the functioning of the Mobile Application  – kept until you delete the Mobile Application from your device. 3. / Access to your location – it is suspended the moment you withdraw your consent. 4. / Accounting and tax purposes – a period of up to 10 years from the date of the last payment. If actions on audits and/or inspections have been taken by the revenue administration and/or other state authorities, the period for storing personal data may be extended by the period of the relevant actions of the state administration.      In order to avoid any undesirable negative consequences in connection with the processing of your personal data, with the expiration of the period for which the personal data is stored, they will be destroyed.    Your personal data may be provided to other persons, depending on the purposes for which the data is stored, namely:  1. / Conclusion, performance of the contract, protection of the rights of the Company in cases of non-performance of the contract and operation of the mobile application of a lawyer, court, prosecutor’s office, SANS, an established courier company, of Bulgarian Posts EAD, of persons responsible for the technical and software maintenance of equipment and operating systems (IT specialists, persons – representatives of operating systems). In case you wish to establish the exact name of the persons to whom your personal data has been provided, please contact us at the e-mail, address and telephone number listed in Section I above. 2. / Accounting and tax purposes – of accountants and accounting firms, of the competent state and municipal authorities at their request, e.g. NRA, MDT Department at the Municipality of Blagoevgrad, SANS, etc. 3. / Statistical purposes – these data are not provided to other persons, with the exception of shareholders representing, employees of the Enterprise and the competent state and judicial bodies and authorities, if necessary and required by them.   ATTENTION: Your personal data may be provided to the Commission for Personal Data Protection when exercising its powers to control compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council.   

  1. / Right of access to, correction, deletion, restriction of processing of your data You have the right to receive information about whether we process your personal data, which  personal data we process, which person processes it, whether it is provided to other persons, for what period it is processed, what are your rights in relation to your personal data and whether you have the right to complain. You may receive a copy of your personal data,  which we process. In addition, you have the right to require us to update/correct your personal data if the information we hold is inaccurate (if, for example, you no longer use the e-mail address provided to us). You have the right to request that we do not perform any actions in relation to your data, but only to store them (the so-called restriction of processing), as well as to request the deletion of your personal data when they are no longer necessary for the purposes for which they are processed, as well as after the expiration of the period for which they are stored. IMPORTANT: You provide your personal data yourself, based on your own decision, and the Municipality of Blagoevgrad does not perform any profiling or automated processing of your personal data.    2. / Right to data transfer You have the right to receive your personal data that you have provided to us and  that we process in a structured and widely used format. In addition, you have the right to transfer your personal data under the preceding sentence to other persons and / or administrators either personally or by transferring the data directly from us to another,  administrator you specify, if technically possible.   The provisions of the  Regulation provide for your right to object in cases where your personal data is processed for the performance of a task carried out in the public interest or where processing is necessary for the purposes or legitimate interests of the Company or a third party, i.e. where the legal grounds for processing your data are based on Art. 6,  1, letters “e” and “f” of the Regulation. In these cases, you have the right to object and request that we stop processing your personal data. If you decide to file such an objection, we will review your request and respond accordingly and within one month, unless a longer period is technologically necessary.   4. / Right to complain You may file a complaint with the Commission for Personal Data Protection, for the protection of your rights and legitimate interests in connection with their processing.   IMPORTANT: In case you need additional information in connection with the collection, processing, storage, destruction or any other information related to your personal data, please contact us at the above address, telephone and e-mail address. Our team will answer all your questions.