Privacy Policy
Extended Warranty Registration Service
1. Data Controller
The controller of the personal data processed through this portal is:
ATN Europe LTD
1588 Sofia Bulgaria ul. "Okolovrasten pat" 456B Inter Logistic Park
In this Privacy Policy, “ATN Europe LTD”, “we”, “us” or “our” refers to the controller named above in connection with the registration and support of extended warranty coverage for ATN Europe LTD products.
For questions about personal data, warranty registration, correction or deletion of data, you can contact us at:
2. Scope of This Policy
This policy explains how we process personal data when you use the extended warranty registration portal.
It applies to the data you provide during registration, data created when the registration is processed, and data needed for verification, support, manual review, warranty service and requests related to personal data.
3. Personal Data We Process
When you register a product through the portal, we may process the following categories of data:
- first and last name
- email address
- serial number or product code
- product model
- purchase date
- store or retailer name, when you provide it or when it is extracted as indicative information from the proof of purchase
- proof of purchase, such as a receipt/invoice image or other accepted proof where required by the portal
- registration status
- data about requested and confirmed consent for optional communication
- date and time of registration submission
- technical information related to use and submission of the form, including IP address, browser language, approximate country signal for the request, and submission date and time when available
Some data are needed to process the warranty registration: first and last name, email address, serial number or product code, purchase date, proof of purchase such as a receipt/invoice image or other accepted proof where required by the portal, and confirmation that you accepted the Terms and Privacy Policy. We record that confirmation as registration evidence. Product model and registration status may be derived or created while the registration is processed. Store or retailer name is optional unless we need it to clarify the proof of purchase.
If required information is not provided or cannot be verified, we may not be able to register, verify, activate or support the extended warranty, or complete your request.
The IP address, browser language and approximate country signal may be used to suggest or display the portal in a more suitable language, make registration easier, maintain portal security and protect the process against abuse.
These data do not represent a confirmed residence address, billing country, purchase country or final language preference.
You should not upload documents that contain more personal data than is necessary to prove the purchase.
4. Purposes and Legal Bases
We process personal data only for specific purposes and according to the applicable legal basis for each purpose.
The main purpose-to-basis mapping is:
- warranty registration administration, activation and necessary warranty, status or service emails: processing needed for the requested warranty service and commercial warranty administration
- proof-of-purchase verification, eligibility checks and manual review: legitimate interests in checking registrations, keeping the warranty process reliable and protecting against mistakes or misuse
- abuse prevention, security, diagnostics, operational records and dispute protection: legitimate interests in secure operation, troubleshooting, accountability and protecting the portal and warranty process
- language selection and localization based on technical signals: legitimate interests in making the portal usable and easier to complete
- privacy, correction or deletion request handling: compliance with applicable legal obligations and, where needed, legitimate interests in verifying and documenting the request
- optional messages about news, special offers and software updates: consent, after you requested the subscription and confirmed it by email
When processing is based on consent, you may withdraw your consent for future messages. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
5. Proof of Purchase and Automated Checks
Uploaded purchase documents are used as proof of purchase for extended warranty registration, manual review, support, warranty service or dispute resolution.
The portal may use automated checks and assisted analysis of the proof of purchase to support the registration process. These checks may help read the purchase date, retailer or other relevant information from the document.
These checks support verification, but they are not intended to be the sole final decision in every case. When information cannot be confirmed automatically, when it is unclear, or when review is otherwise needed, the registration can be sent for manual review by an authorized person.
Before storage, the portal removes EXIF metadata from uploaded images when technically possible.
6. Storage and Service Providers
In the current version of the portal, registration data may be stored in Google Sheets as a working system for managing registrations.
Photos of proof-of-purchase documents may be stored in Google Cloud Storage as proof of purchase needed for verification, manual review, support or later warranty service.
For portal operation, we may use providers of technical infrastructure, hosting, storage, email delivery, document analysis, security and support. When these providers process personal data on our behalf, they act as processors under applicable contractual and technical safeguards.
Depending on the providers used for portal operation, personal data may be processed in or from locations outside the European Economic Area where applicable. In those cases, appropriate safeguards may include an adequacy decision, standard contractual clauses or another mechanism permitted by applicable law. You can request more information about applicable safeguards through:
7. Who Has Access
Access to registration data is limited to authorized persons and protected internal systems when needed for:
- administering warranty registrations
- checking proof-of-purchase documents
- manual review of a registration
- customer service
- warranty service
- processing requests related to personal data
- technical support, security and protection against abuse
Photos of proof-of-purchase documents are not published as public links. Access to them is restricted and takes place only through protected internal processes.
8. Optional Communication, Software Updates and Unsubscribe
Communication about news, special offers and software update notices is optional and separate from warranty registration.
If you choose to receive such messages, the subscription is considered complete only after email confirmation.
Unsubscribing from this subscription does not delete the warranty registration and does not affect warranty service. It affects only optional messages.
ATN Europe LTD may send separate necessary messages related to warranty, service, security, important product information or legal obligations where applicable. Such messages are not treated as optional marketing communication.
9. Retention Period
We store personal data only for as long as needed for the purposes for which they were collected, including warranty administration, support, accountability, abuse prevention and protection against possible disputes.
Registration data may be stored during the warranty coverage period and for an additional period when needed for legal obligations, accountability, warranty claims, disputes or protection of legitimate interests.
The normalized caller IP address and related technical data are stored only insofar as they are needed for warranty registration, security, abuse prevention, diagnostics, accountability or protection against possible disputes.
Proof-of-purchase documents are stored only while there is an operational reason for this, including verification, manual review, support, warranty service or dispute resolution.
When there is no longer a basis for storage, data are deleted, anonymized or retained only in a limited form where this is permitted and necessary under applicable law.
10. Anonymized Data and Statistics
After the necessary retention period expires or when an applicable deletion request is fulfilled, some data may be deleted and other data may be retained only in anonymized or aggregated form where permitted.
When anonymizing, data that can identify a specific person or registration are removed or irreversibly separated, including name, email address, IP address, serial number, registration identifiers, tokens, links to proof-of-purchase documents and the uploaded documents themselves when they are no longer needed.
Anonymized or aggregated data may be used for statistics, internal reporting and process improvement without being used to re-identify a specific person.
11. Your Rights
Depending on the specific case and applicable law, you have the right to request:
- access to the personal data we process about you
- correction of inaccurate or incomplete data
- deletion of personal data
- restriction of processing
- objection to certain processing
- data portability where applicable
- withdrawal of consent where processing is based on consent
Requests related to personal data are handled without undue delay and within up to one month from receipt. Where the request is complex or multiple requests have been received, the period may be extended under applicable law, and you will be informed of this.
You can submit a request through:
To protect your data, we may ask for additional information needed to confirm your identity or clarify the request.
12. Deletion Requests
You may submit a request to delete personal data. The request will be reviewed according to applicable law and the specific case.
In certain cases, we may be required or entitled to retain part of the information, for example where this is necessary for legal obligations, warranty service, accountability, abuse prevention or the establishment, exercise or defense of legal claims.
The portal does not provide an immediate automatic self-service deletion process. Requests are reviewed and processed by an authorized person.
If a request was submitted by mistake, you can contact us as soon as possible. Where the system provides a link to cancel a request, it may be used within the period stated in the relevant message.
13. Right to Lodge a Complaint
You have the right to lodge a complaint with the competent data protection supervisory authority if you believe that the processing of your personal data violates applicable law.
For Bulgaria, the competent supervisory authority is the Commission for Personal Data Protection.
14. Changes to This Policy
This policy may be updated when there are changes to the portal, registration process, providers used or applicable rules.
Where a change is material, appropriate steps will be taken to inform users when required by applicable law.