Privacy Policy
1. Who processes the data
The controller of the Customer Score service is:
SIT-TRADING EOOD
UIC: 203335995
Address: 16A Besarabia St., Sofia, Bulgaria
Email: info@t-auto.bg
2. What Customer Score is
Customer Score is a service designed to assist online merchants in managing risks related to order deliveries, including cash-on-delivery shipments.
Through the service, registered merchants can perform a lookup by phone number and receive information about available delivery history associated with that number.
3. What data we process about shipment recipients
Customer Score is designed in accordance with the principle of data minimisation.
For shipment recipients, the system does not require storage of a name, national personal identification number, physical address or email address.
The following may be processed:
- phone number;
- technical identifier/hash of the phone number;
- delivery status;
- date of the relevant event;
- shipment value;
- courier;
- order or shipment identifier;
- a limited description of the shipment contents where necessary.
4. What data we process about merchants
When access to Customer Score is requested, the following may be processed:
- name of a contact person;
- business email address;
- contact phone number;
- website;
- technical data relating to API usage.
5. What we use the data for
Delivery-related data is processed for the purposes of:
- providing information about delivery history associated with a specific phone number;
- calculating a statistical risk score;
- assisting merchants in managing the risk of unclaimed or refused shipments;
- preventing misuse of the service;
- maintaining the accuracy and security of the system.
6. Customer Score and profiling
Based on delivery history, the system may automatically calculate a statistical score called Customer Score.
The score may take into account factors such as successfully received deliveries, unclaimed or refused shipments and the age of the events.
The purpose of the score is to provide the merchant with additional information about the risk associated with a particular delivery.
7. Source of the information
Delivery-history information is provided by merchants that use Customer Score.
Merchants should submit only information related to genuine orders and deliveries.
8. Legal basis
Data processing must be carried out only where an applicable legal basis exists under Regulation (EU) 2016/679.
Where processing is based on legitimate interests, the purpose is to limit financial losses and misuse related to unclaimed or refused deliveries while applying safeguards for the rights and interests of natural persons.
A different legal basis may apply to individual processing operations, depending on the specific circumstances.
9. Data minimisation
Customer Score seeks to process only the information necessary to provide the service.
The purpose is not to create a detailed profile of a natural person, but to assess a specific delivery history associated with a phone number.
10. Retention period
Data is not retained indefinitely.
Customer Score determines retention periods and periodically reviews the data. Older events may carry less weight when calculating the score or may be deleted after the applicable retention period expires.
Specific retention periods may be changed depending on necessity, applicable law and the purposes of processing.
11. Who has access to the information
Access to Customer Score is granted only to registered and authorised merchants.
The service is not a public database and does not allow unrestricted public searches of phone numbers.
API access is provided through individual identifiers and keys.
12. Sharing of information
Data may be processed by providers of technical infrastructure, hosting and other services where necessary for Customer Score to operate and where the appropriate contractual and technical safeguards are in place.
Customer Score does not sell phone numbers or delivery history for marketing purposes.
13. Security
Appropriate technical and organisational measures are applied to protect the information, including access controls, HTTPS communication, individual API keys and restrictions on access to the database.
Where possible, identifiers may be pseudonymised or hashed.
14. Correction of inaccurate information
Because information is provided by different merchants, inaccurate or incorrectly linked information may occasionally be submitted.
A person who believes that information associated with their phone number is inaccurate may request verification and correction.
Requests may be sent to: info@t-auto.bg.
15. Your rights
Subject to applicable law, natural persons may have the right:
- to receive information about the data being processed;
- to request access to that data;
- to request correction of inaccurate data;
- to request erasure where the applicable grounds are met;
- to request restriction of processing;
- to object to certain types of processing;
- to exercise rights relating to automated processing and profiling;
- to lodge a complaint with the competent supervisory authority.
16. How to exercise your rights
To prevent information from being disclosed or changed for the wrong person, where a request for access, correction or erasure is made, we may need to confirm that the requester actually controls the relevant phone number.
This may, for example, be done through a verification code sent by SMS, without requiring additional identity documents where they are not necessary.
17. Complaint to a supervisory authority
Natural persons have the right to lodge a complaint with the competent data protection authority, including the Commission for Personal Data Protection of the Republic of Bulgaria.
18. Changes to this policy
This policy may be updated where Customer Score functionality changes, where the way data is processed changes, or where applicable law changes.
The current version will always be published on this page.
19. Contact
For questions about personal data protection: info@t-auto.bg.