Privacy Policy

This Privacy Policy and Privacy Protection of Brunata Ltd ("Privacy Policy") is based on the requirements of Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Individuals with regard to Privacy to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC ("Regulation (EC) 2016/679").

This Privacy Policy applies to your personal data that Brunata Ltd. processes in order to provide you with services according to the subject matter of the organization. It is also relevant to the personal data processed on the website www.dalsiabrunata.bg.

This Privacy Policy aims to explain why and how we process and protect your personal information in a clear and understandable way.

Who are we and how can you contact us?

Brunata OOD

85 Br. Baxton Blvd

1618 Sofia

tel. 02 9155 701

To contact our Data Protection Officer, you can send an e-mail to: This email address is being protected from spambots. You need JavaScript enabled to view it. or contact us by post at: Brunata Ltd, 85 Br. Baxton Blvd, 1618 Sofia, Bulgaria - and write the following text: to the attention of Brunata OOD's data protection officer.

What kind of personal data do we collect and process?

We process your personal data in compliance with the applicable law - in a lawful, conscientious and transparent manner. We collect the minimum amount of personal data limited to the purposes for which they are needed.

As an administrator, and in some cases also as a personal data processor, Brunata Ltd. strives to provide an adequate level of data protection to its clients and to process them in accordance with current legislation.

Depending on the specific purposes Brunata Ltd. processes and collects the following data individually or in combination:

• Personal data provided by you for the identification and fulfillment of contractual obligations: names, PIN, date of birth, address, telephone, e-mail, subscriber number to the heating company;
• Personal data provided through our online platform when registering and completing different forms: names, address, phone, e-mail, IP addresses, logs, cookies;
• Personal data provided by you through job applications, letters, complaints and other feedback we receive from you;
• Video recordings - when performing security activities to protect the security of customers and employees in the company's offices and to improve service.

Bruna Ltd. processes personal data in different ways. As a data administrator, Brunata uses the data only for provision of contracted activity, customer service, feedback and marketing purposes. Data advertising is only possible for the purposes of our own market research and advertising. We do not provide this data to third parties without your explicit consent unless it is a matter of fulfilling a legal obligation or protecting the legitimate interests of the Company.

As personal data processor, your personal data will be provided to Brunata OOD by district heating companies, water and sewerage companies, metrological laboratories, natural and legal persons and / or their proxies / representatives, authorized by the buildings - condominiums, as well as upon receiving requests from state authorities for information.

What are the purposes and legal bases for processing your personal data?

Brunata Ltd. processes your data for the following purposes:

1. Performing contractual obligations and services, as well as for managing relationships with our service customers.

2. In order to perform our heat cost allocation services and the accompanying customer service in regard to complying with the related legal obligations of Brunata - the Energy Act, the Ordinance on district heating, the General Conditions of district heating companies, as well as for performance of our contractual obligations to which the relevant person is a party. The processing of personal data is also necessary in order to fulfill our obligations in the field of tax and accounting legislation.

3. Creating and managing a profile on our corporate site and online Brunata services

4. Personal data in accordance with the Regulation may be processed for the purposes of the legal interests of Brunata, including the legal protection of / legal claims of / against the company.

We process your personal data lawfully, fairly and in a transparent manner. We limit the personal data collection and gather only the minimum needed and relevant to the processing goals. We make sure that the data is accurate and up-to-date. We ensure confidentiality of processing and an adequate level of personal data security.

How long do we keep your personal data?

Brunata is obliged to store the necessary personal data for the period of the contractual relations with us, as well as with the district heating and/or water supply companies and/or the heat consumers and recipients of the heat distribution shared service, taking into account the limitation periods provided by the legislation. In pending lawsuits, claim proceedings and/or others personal data may be stored for a longer period and as long as necessary.

Personal data are subject to removal in an appropriate security and confidentiality manner upon expiration of the legal or contractual grounds for processing them. You may withdraw your consent to the processing of your personal data when processing is solely based on your consent.

Third-party categories of recipients of personal data:

In accordance with the requirements of EU Regulation 2016/679, Brunata OOD has the right to disclose personal data information to third parties only if it is necessary for the performance of the assigned activities and is subject to a written agreement that guarantees that the processors will comply with all legal obligations for the protection of personal data.

Personal data can be provided to administrators and personal data processors - district heating companies, government bodies. Personal data may also be provided to subcontractors performing services on our assignment (courier services, metrological inspections, IT services, lawyers, etc.).

Brunata OOD strives to take all necessary measures to ensure that processors strictly comply with data protection laws and instructions and that they have taken appropriate technical and organizational measures to protect your data.

Security measures for data protection:

We are committed to ensure the security of your personal data by applying the following measures:

• appropriate organizational requirements
• technical measures for physical protection
• protection of automated information systems and networks
• personal protection measures
• regulatory and administrative measures.

Regular reviews of all procedures and rules for data processing, including system security measures, are performed.

What are your rights regarding the processing of personal data by Brunata OOD?

As a customer you have the following rights in relation to your personal data:

• Information and access to your own personal data;
• Correction (if data is inaccurate);
• Restriction on the processing of personal data;
• The right to data portability;
• Deletion of personal data (the right to be forgotten) if there is a legal basis for this;
• Objection to the processing of your personal data;

To exercise your rights, Brunata may ask you to verify your identity by requesting you to provide us with an ID.

The conditions under which those rights may be exercised are governed by Chapter III (Articles 12 to 23) of the Regulation.

You are also always entitled to legal or administrative redress if your rights have been violated. To do this you must file a complaint with the local supervisory authority about the processing of your personal data. In Bulgaria, this is the Commission for the Protection of Personal Data (CPDP). Its address is as follows: Sofia, 2 Prof. Tsvetan Lazarov Blvd., tel. 02 / 91-53-515, 02 / 91-53-519. E-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it..