This Privacy Policy explains how PAN DIGITAL GROUP OOD, operating under the Digital Agent brand, collects, uses, stores and protects personal data when users interact with digitalagent.bg, the Digital Agent platform, Meta/Facebook Login for Business, WhatsApp Business Platform, AI communication services and related functionality.
1. Data Controller and Service Operator
PAN DIGITAL GROUP OOD Company ID: 205890020 VAT No.: BG205890020 Address: 104 Knyaz Boris I St., Parvomay, Plovdiv Region, Bulgaria Website: https://digitalagent.bg/ Email: info@digitalagent.bg
Depending on the service provided, Digital Agent may act:
as a data controller where we determine the purposes and means of processing;
as a data processor acting on behalf of a business client, where a hotel or another business uses Digital Agent to communicate with its customers.
Where Digital Agent acts as a processor, the relevant business client remains the data controller and determines the purposes of the processing.
2. Services Covered by This Policy
This Privacy Policy applies to:
digitalagent.bg;
the Digital Agent platform;
AI chat and communication agents;
WhatsApp Business Platform;
Meta/Facebook Login for Business;
Meta Embedded Signup;
customer conversation management;
reservation and follow-up automations;
CRM and PMS integrations;
analytics dashboards;
WhatsApp message templates;
marketing automation;
other Digital Agent services and integrations.
3. Data We May Process
3.1. Business Client Data
We may process:
first and last name;
business email;
telephone number;
company and job title;
business account information;
user roles and permissions;
contractual information;
login and activity logs.
3.2. Meta and WhatsApp Data
When a business connects its Meta Business Portfolio or WhatsApp Business Account to Digital Agent, we may process:
Meta Business Portfolio ID;
WhatsApp Business Account ID (WABA ID);
WhatsApp Business Phone Number ID;
business and display names;
connected business phone numbers;
phone number quality and status information;
message template information;
message identifiers and statuses;
delivered, read, failed and other message statuses;
authorization codes and access tokens;
other Meta Platform Data required to provide the authorized service.
Access to such data is obtained only after explicit authorization by the relevant business through Meta’s official authorization mechanisms.
3.3. WhatsApp Conversations
When a person communicates with a business using Digital Agent, we may process:
WhatsApp identifier and/or phone number;
sender name where available;
message content;
files and media;
timestamps;
delivery and read statuses;
conversation history and context;
AI-generated summaries or conversation classifications.
4. Reservation Data
Where Digital Agent is used for hotel or other reservations, the following may be processed:
name;
phone number;
email;
requested dates;
number of guests;
children’s ages where required to provide a quotation;
selected room or service;
preferences;
reservation number and status;
other information voluntarily provided during the conversation.
5. How We Use Data
We use data to:
provide and maintain Digital Agent;
connect Meta and WhatsApp Business Accounts;
send and receive WhatsApp messages;
route conversations to the appropriate business and AI agent;
provide customer service;
check availability and manage reservations;
send booking confirmations;
provide follow-up communication;
manage WhatsApp message templates;
send permitted marketing communications;
provide analytics and reporting;
maintain security and prevent abuse;
provide technical support;
meet contractual and legal obligations.
6. Legal Bases for Processing
Depending on the circumstances, processing may be based on:
performance of a contract;
steps taken prior to entering into a contract;
legitimate interests;
compliance with legal obligations;
consent;
instructions from a business client where Digital Agent acts as a processor.
7. Use of Artificial Intelligence
Digital Agent uses AI technologies to:
understand customer enquiries;
generate responses;
extract and structure information;
summarize conversations;
classify customer intent;
assist with reservation processes;
perform automated follow-up actions.
Where necessary, parts of communications may be processed by AI and cloud service providers subject to appropriate technical and contractual safeguards.
Digital Agent does not sell personal data or Meta Platform Data to advertisers or other third parties.
8. Meta and WhatsApp
When a business connects its WhatsApp Business Account:
the business completes Meta’s official authorization process;
the business selects and authorizes the business assets Digital Agent may access;
Digital Agent uses that access solely to provide the authorized service;
the business may revoke access.
Meta Platform Data and WhatsApp data are used only to provide, maintain, secure and improve the functionality authorized by the customer.
9. Meta/WhatsApp Deauthorization
If a business removes or deauthorizes Digital Agent:
active access tokens are revoked or deleted;
the active WABA connection is disabled;
active WABA ID and Phone Number ID mappings are removed where no longer required;
messages are no longer routed through the disconnected integration.
Limited audit information may be retained where necessary for security, accountability or legal obligations.
10. Sharing of Data
Data may be processed by service providers required to operate Digital Agent, including:
Meta Platforms / WhatsApp;
cloud infrastructure providers;
AI technology providers;
communication service providers;
hosting, database and monitoring providers;
CRM and PMS systems selected by the customer;
professional advisers;
competent public authorities where legally required.
We limit disclosure to information necessary for the relevant purpose.
11. International Data Transfers
Where providers process information outside the European Economic Area, applicable data transfer safeguards may be used, including adequacy decisions or Standard Contractual Clauses where required.
12. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected.
Retention depends on:
the duration of the client relationship;
service requirements;
customer retention settings;
legal obligations;
security requirements;
the need to establish or defend legal claims.
Meta authorization data is removed or disabled when access is revoked or no longer required.
13. Data Deletion Requests
Users may request deletion of their personal data by contacting:
Please provide enough information for us to identify the relevant account or communication without providing unnecessary personal information.
Digital Agent also maintains automated mechanisms for processing Meta deauthorization and Meta data deletion requests.
Where Digital Agent acts as a processor for a business customer, we may refer the request to the relevant controller or assist the controller in fulfilling it.
14. Your Rights
Subject to applicable data protection law, you may have the right to:
access your personal data;
correct inaccurate data;
request deletion;
restrict processing;
object to certain processing;
data portability where applicable;
withdraw consent;
lodge a complaint with a competent supervisory authority.
The competent supervisory authority in Bulgaria is the Commission for Personal Data Protection.
15. Marketing Communications
Marketing and follow-up communications are sent only where an appropriate legal basis exists and in accordance with applicable WhatsApp rules.
Recipients may request that future marketing communications stop.
Digital Agent may record such preferences and use them to prevent further unwanted marketing communications.
16. Security
We apply appropriate technical and organizational security measures, including where applicable:
HTTPS encryption;
access controls;
separation of customer accounts and data;
credential and access token protection;
signed callback verification;
audit logging;
monitoring;
backups and incident response procedures.
17. Cookies
Digital Agent may use cookies and similar technologies for:
website functionality;
authentication;
security;
preferences;
analytics.
Where consent is legally required, relevant cookies are used only after consent has been provided.
18. Children’s Data
Digital Agent is a B2B service and is not intended for independent use by children.
Information relating to children, such as a child’s age when making a hotel reservation, is processed only where necessary to provide the requested service.
19. Changes to This Policy
We may update this Privacy Policy following changes to:
our services;
integrations;
applicable law;
requirements imposed by Meta or other service providers.
The latest version will always be available at:
https://digitalagent.bg/privacy-policy
20. Contact
PAN DIGITAL GROUP OOD Company ID: 205890020 VAT No.: BG205890020 104 Knyaz Boris I St. Parvomay, Plovdiv Region, Bulgaria