General Terms and Conditions for using the Kaksi mobile application and the services offered through it

I.                    General information.


1. DZI - Life Insurance JSC, UIC 121518328, with registered office and address of management: Sofia, 89B “Vitosha” Blvd., engages in insurance activity in accordance with the Insurance Activity Permit № 2/13 May 1998 and uses the website


2. The Supervisory Authority of the Insurance company is the Financial Supervision Commission, with address: Sofia, 16 “Budapest” Street.


3. kaksi provides services related to improving the health of the consumer through a smart algorithm for analysis of consumer activity, access to health advice and articles, providing special offers from DZI - Life Insurance JSC, DZI - General Insurance JSC and other partners, as well as access to the health insurance services of DZI-Life Insurance JSC through a digital health card, access to online portals for medical services - after identification as a client of DZI-Life Insurance JSC, which can be based on applications or web-based services ("Mobile services"). These mobile services are provided free of charge and can be used by all registered Users.


4. These General Terms and Conditions govern the relationship between DZI - Life Insurance JSC, on the one hand, and the Users of the mobile application, on the other hand, in connection with the installation and use of the mobile application and the services provided by it.


II.                  Registration and installation.


1. The application is available for download and installation on a mobile end device in the Google Play Store and Apple Store. For the normal use of the Application it is necessary to have end devices (smartphones) of Users running Android 10, iOS 13 operating systems and newer software versions, as well as an Internet connection - mobile or wireless (Wi-Fi). If the User does not have the appropriate software, hardware and/or internet connection, the use of the application will be hindered. Data traffic when using the application, both in Bulgaria and in roaming, is charged and rated according to the terms of the subscription or prepaid plan used by the User and the current price list of the service operator.

2. In order to successfully register in the mobile application, it is necessary for the User to provide his/her phone number to which he/she will receive an activation code. The initial registration in the mobile application is done by entering a phone number and filling in the unique activation code, which the mobile application sends to the User in the form of an SMS. The mobile application allows to maintain only one active session from one mobile device.           


III.                Acceptance and consent.


1. The User must carefully read these General Terms and Conditions before marking his/her consent to them and continue the registration process in the mobile application. If the User does not agree with any of the provisions of these General Terms and Conditions, he/she will not be able to access or use the mobile application, nor the software, services, information or any of its functionality.


2. The use of the services in the mobile application is based on these General Terms and Conditions. By checking the appropriate field during the initial registration, the User:

2.1. agrees that this electronic statement is his/her electronic signature within the meaning of the Electronic Document and Electronic Certification Services Act;

2.2. expressly agrees that the legal force of the electronic signature thus provided by him/her is equivalent to the legal force of his/her handwritten signature;

2.3. expressly agrees and is bound by these General Terms and Conditions.


3. In the event that after registration in the mobile application the User decides that he/she does not agree with any of the provisions of these General Terms and Conditions, the User must uninstall the mobile application. The absence of such uninstallation, respectively the use of the mobile application, means that the User agrees with the General Terms and Conditions at any time from their acceptance to the uninstallation of the mobile application.


4. DZI - Life Insurance JSC has all the rights to the mobile application necessary for its proper use. Nothing in these General Terms and Conditions shall be construed as granting any rights for the benefit of Users other than the right to use the services in the mobile application in accordance with the conditions detailed below in this document and in documents to which these General Terms and Conditions refer.


5. In case of change of the present General Terms and Conditions, DZI - Life Insurance JSC notifies in advance the Users of the mobile application, who explicitly state their consent and commitment to the texts of the new General Terms and Conditions.


6. DZI has the right to unilaterally change these General Terms and Conditions without notifying the User in advance when the changes concern the technical requirements for use of the mobile application, change of the scope of its functionalities, publication of new versions.


IV.                Definitions and terminology.


Mobile application user - a natural person who has installed the mobile application and has successfully registered in the Application.

Server – a device or system of connected devices on which or on any of which system software is installed to perform tasks related to storing, processing, receiving or transmitting information.

Electronic document – content, text recording stored in electronic form on magnetic, optical or other media that can be reproduced.


V.                  Completeness and accuracy of information. Limitation of liability.


1. DZI - Life Insurance JSC shall not be liable in case of non-fulfillment of its obligations for the provision of services, which occurred due to extraordinary technical or communication reasons such as, but not limited to, failure of information systems, interruption of communication lines, power outage, etc., as well as in extraordinary circumstances such as natural disasters, nationwide strikes, technical damage, which are beyond the control of the Company.


2.  DZI - Life Insurance JSC is not responsible for incorrect, inaccurate or unscrupulous data entered by the User.


3. DZI - Life Insurance JSC is not liable for damages caused by circumstances beyond the control of the Company, such as, but not exhaustively: in case of irresistible force, accidental event, force majeure, problems related to access and internet connection, of problems due to the Client's equipment, as well as in case of unauthorized access or intervention of third parties.


4. DZI - Life Insurance JSC shall not be liable for damages caused to the software or hardware of the Users or for loss of data in connection with the use of the mobile application.


5. DZI - Life Insurance JSC shall not be liable for damages resulting from the use of third party personal data by another third party, in violation of these Terms and Conditions, as well as for inaccurate or incorrectly provided data and information.


VI.                User types.


The Mobile application differentiates between two types of Users - standard Users and Premium users.


1.       Standard Users.

Standard Users have unlimited access to the Mobile application and its functionalities, incl. standard offers in DZI Store, except for special offers in DZI Store, valid only for Users with premium status.


2.       Premium Users.

Premium Users can benefit unlimitedly from the features of the Application, including access to special offers in DZI Store, valid only for this class of Users.


In order to be able to switch from Standard User status to Premium User status, the User needs to digitize his/her "Health" health insurance card "Health" or "Comprehensive medical care" through the functionality "Add DZI Health Card".



VII.              Functionalities and services.


1.         News.

1.1. The Mobile application provides a service for access to information provided by DZI - Life Insurance JSC, DZI - General Insurance JSC and their partners.

1.2. The copyrights on the materials published in the "News" section are wholly and solely the property of the providing party.

1.3. DZI - Life Insurance JSC is not responsible for the information provided by other parties and published in the kaksi Mobile application.



2.       Notifications and notification management.

2.1. The Mobile application allows Users to receive notifications about:

·      Emergency contact signals

·      Notifications for new friends and registration via a user link

·      New quizzes

·      New publications in the News section

·      New offers in DZI Store

·      DZI Energy, activities and training

·      General notifications

·      Direct marketing

·      Health notices

2.2. Each User can actively manage the notifications to be received, according to the categories described above.

2.3. The management of personal preferences for receiving notifications is performed through the "Management of notifications" section in the "Menu" submenu in the Mobile application.


3.     SOS signal and emergency contacts.

3.1. The application provides a service for notifying emergency contacts in case of need, incl. submitting an exact or last known location.

3.2. In case of urgent need for help, the User can activate the SOS signal function. Activation allows the User to generate a call to 112, as well as notification of his/her emergency contacts. The User chooses his/her emergency contacts. All emergency contacts who are kaksi users are sent a notification containing the geo-location of the User who sent the signal, as well as the Health file of the latter, in case the User has explicitly allowed the Mobile application to send personal information. An SMS notification with the GPS coordinates of the person who sent the signal is sent to the emergency contacts who are not Users of the application.

3.3. In order to be able to generate an SOS signal, the User needs to have access to the Internet (Wi-Fi or mobile data). The app also provides the ability to locate people added to the app and give their consent to be contacts through the "Find my friends" feature. This feature allows Users to retrieve the exact geo-location of all added friends on request.

3.4. Location information, i.e. GPS coordinates of the User are stored locally and are extracted from the factory built-in functions of the mobile phone, i.e. applications.


4.     Invite friends.

The Mobile application allows Users to add their friends to the application. It is necessary for the User to provide access to his/her phonebook in order for the application to recognize and classify the contacts as Users of the Mobile application, providing a direct opportunity to add them as Friends or as contacts who are not Users of the Application, allowing sending invitation to join.

The Mobile application encourages Users to send invitations to join third parties who do not have active registration in the application, rewarding Users with DZI Pearls.


5.     Activities.

5.1. Mobile application Users can track their physical activity as well as various health metrics in the Mobile application, giving their consent for the mobile application to access the information from the software health applications built by the operating system manufacturer (e.g. Apple Health, Google Fit etc.).

5.2. The health information visualized in the Mobile application in the "Activities" section, with the exception of DZI Energy, is calculated, recorded and processed by the User's device and the Mobile application is not responsible for its accuracy.

5.3. DZI Energy is a smart algorithm based on historical information about the levels of physical activity of consumers, and it is changed every day in order to motivate consumers to increase their physical activity. DZI Energy calculates information on the levels of physical activity, reading the data from the built-in health applications developed by the software solution providers for the respective operating system.


6.    Training.

Each User of the Mobile application has the right to create personal training when running or walking, with which to track the route, distance traveled, displacement and training time. For this purpose, the Mobile application connects to the built-in health application, as well as to the built-in geo map of the User's device in order to be able to visualize the route and activity information.


7.     Avatar.

7.1. The Mobile application allows each User to create their own unique Avatar. The avatar is a dynamically changing 3-D visual element that is directly related to the levels of physical activity achieved by the User.

7.2. When increasing the physical activity, according to the levels set with DZI Energy smart algorithm, the User increases the level of his/her Avatar. In case of failure to achieve the algorithm set with DZI Energy, the User lowers the level of his/her Avatar.

7.3. Each subsequent higher level of Avatar allows the User to accumulate more DZI Pearls in achieving the daily goals set by the DZI Energy algorithm.


8.     Quizzes.

The Mobile application allows Users to earn additional DZI Pearls also by participating in various quizzes with topics related to the content published in the "News" section.

Each correct answer is rewarded by the Mobile application with additional DZI Pearls, the number of which is predetermined.


9.     DZI Pearls.

9.1. DZI Pearls is a kind of digital currency in the Mobile application which allows Users to accumulate it through various activities. Consumers can convert their DZI Pearls into offers suggested by DZI - Life Insurance JSC, DZI - General Insurance JSC and partners in the DZI Store section.

9.2. DZI Pearls is not an equivalent or alternative to any other existing digital or physical currency, cannot be converted to one and cannot be used outside the Mobile application.


10.  DZI Store.

10.1. DZI Store provides an opportunity for the Users of the Mobile application to convert the accumulated DZI Pearls into offers, discounts, bonuses, gifts, prizes and participations in various raffles.

10.2. If the User agrees to take advantage of offers in the Mobile application suggested by a third party - partner of the Mobile application, DZI - Life Insurance JSC is not responsible for the quality and serviceability of the offered goods and/or services. Questions and/or complaints in connection with the goods and/or products offered by third parties - partners are addressed directly to the third party - partner offering them. All clients can send signals for merchants who have not provided the discounts offered by them to the email, as well as call the DZI Customer Service Center at 0700 16 166.


11.  Health record.

11.1. Each User of the Mobile application can create their own health record in which to fill in information about:

·      Blood type

·      Allergies to food and beverages

·      Drug allergies

·      Diseases

·      Regular medication

11.2. The health record can be sent to the User's Emergency Contacts in case of an SOS signal. To this end, the User should have given explicit permission for the Mobile application to send the information from his/her health record to third parties.


12.  Personal information.

In the Personal Information section the User can fill in their:

·      First Name

·      Last name

·      Phone number

·      Health card number

·      Email address to restore access to the mobile application in case the User changes his/her phone number

·      Date of birth

·      Gender


13.  Access to health services (DZI ‘s Digital Health Portal, Healee and Superdoc).

Through the kaksi Mobile application, Users can access the range of digital health services that DZI - Life Insurance JSC provides through its own digital channels, as well as through established partnerships with third parties. The services are accessed through a link leading to the external service.


14.  Digital health card.

Through the kaksi Mobile application, the Clients of DZI - Life Insurance JSC with active "Good Health" or "Comprehensive Medical Care" health insurance can digitize their health card. Activation is performed by two-factor identification. It is necessary for the consumers to enter, in the first step, their health card number provided to them by DZI - Life Insurance JSC, as well as their surname - in the second step.


15.  Feedback.

The Mobile application provides Users with the opportunity to send feedback to developers and DZI - Life Insurance JSC.


16.  Account deleting.

16.1. Each User has the right to delete their account in the Mobile application at any time. This action will delete all personal information that the owner and developer of the application store for the User.

16.2. After deleting the account and re-registering with the same phone number, the mobile application will not keep the previously provided information by the User, incl. availability of DZI Pearls, Avatar level and others. All available information is deleted from the servers of the Mobile application when deleting the account.


VIII.            Information about personal data protection.

  1. The company DZI - Life Insurance JSC, UIC: 121518328, address: Sofia, 89B Vitosha Blvd., in its capacity of Personal Data Administrator, carries out its activities in strict compliance with the requirements of the Law on Protection of personal data and "Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data" (the "Regulation").

    2. For the purposes of installing and using a DZI Mobile application, the Company processes your personal data on the following legal grounds:

    а) Consent.

    Processing for purposes for which your consent is required is voluntary. Without your consent, we may not process your personal data for the purposes of using the mobile application. In case you do not proceed to registration in the mobile application, your data will not be processed and stored by DZI, as the information entered by you will be visible only to you and will be stored on your mobile device.

    Upon your registration and consent, the application automatically (without your or the Administrator's human intervention) decides for you to activate all notifications and provide them - notifications, messages and others - in the menu "Notification Management". According to your wishes and interests, you can immediately after registration or during the entire use of the application, enable, disable and manage each of these features by deactivating them in the "Manage notifications" menu.

    In case you refuse to give your consent to the processing of personal data, you will not be able to complete your registration in the application, through which your health card will be transformed into a virtual one and will allow you to take advantage of the bonus points available in the application and valid for the purchase of insurance products of your choice, special promotional offers from DZI partners, as well as a link to a website to book an appointment for consultation or filing an online claim.

    Important: You can withdraw your consent at any time in accordance with the instructions set out in item 11.5 of these General Terms and Conditions, as well as when deleting the account and your data contained therein.

    b) Fulfillment of legal obligations.

    The processing ensuring fulfillment of legal obligations is necessary, for example, when the law stipulates obligations of the Administrator to retain or provide information upon receipt of a relevant order from the competent state or judicial authorities, while providing an opportunity to exercise the control powers of the competent government agencies and in the performance of legal obligations to retain and/or provide information related to you.

     c) Legitimate interest.

    The processing for the purposes related to the protection and implementation of the legitimate interests of the Administrator is necessary for the protection of his/her legitimate interests and/or of his/her contractors, as this is balanced in an appropriate way with your interests, as the data processing takes place within the scope strictly necessary for communication with you on issues related to the application, as well as for administration and servicing of received signals, complaints, requests and other correspondence and for realization and protection of the rights and legal interests of the Administrator.


    3. By installing the Mobile application, each User should agree to the General Terms and Conditions of the application. DZI will process the data of the Users who have installed the application, and the data will be stored as follows, depending on their category:

    3.1. Your mobile device stores health information provided by the activity software application built into the mobile device (e.g. Apple Health, Samsung Health, Google Fit, etc.)

    3.2. The servers of the following DZI contractors - Sirma ICS JSC, DATICUM JSC and AKTA LTD, DZI will store the following categories of your personal data: telephone number (always), name, surname, email address, date of birth, gender (if provided) and such data only to identified clients of DZI - Life Insurance JSC - health card number, DZI Energy, Avatar level, DZI Pearls (balance), health record, consents granted, offers taken from DZI Store, participation in quizzes, friends, emergency contacts.

    3.3. The categories of data that are processed by DZI for the purposes of using the Mobile application are divided into the following, according to the quality in which the User operates:

    А) For users who use the application without identifying themselves as clients to the Administrator - DZI and who are not insured persons who have an active Good Health or Comprehensive Medical Care health insurance, DZI will process the following categories of personal data:

    •             First name

    •             Last name

    •             Phone number

    •             Email address

    •             Date of birth

    •             Gender

    B) For Users who use the application and have identified themselves as insured persons to the Administrator - DZI and who have an active Good Health or Comprehensive Medical Care health insurance, DZI will process the following categories of personal data:

    ·                 Health card number;

    C) All Users may additionally enter the following optional categories of personal data in the application:

    ·                   Allergies to food and beverages

    ·                   Blood type

    ·                   Drug allergies

    ·                   Diseases

    ·                   Regular medication

    ·                   Geolocation

    The listed categories of personal data are optional in order to use the Mobile application, and to enter them, the User of the application expresses explicit consent by declaring that he/she is familiar with and accepts these General Terms and Conditions.


    4. By digitizing their health card Users confirm that they are familiar with and agree to these General Terms and Conditions, and that they agree that the personal data provided can be processed by the Administrator for the purposes specified therein.


    5. For the Users of the application who have identified themselves as clients of DZI and insured persons, DZI will provide them with special offers and promotional initiatives implemented on the Internet, as the Administrator uses a legal basis for the processing of personal data within the transmission of such data. - consent within the meaning of Article 6 (1) (a) of the GDPR.

    The purpose of processing your data as a User who has digitized their Health or Comprehensive Medical Care health insurance card through the functionality "Add DZI health card" is to obtain information about games with prizes, special offers, promotional initiatives, discounts, new services, loyalty programs and facilitated use of the same. By checking the box for agreement with these rules and subsequent digitization of your Health Card, you confirm your consent to the processing of your personal data for the specified purpose. After your registration you will receive notifications from us in the application you use.

    You can withdraw your consent to receive promotional offers from DZI at any time with effect from now on by sending an email to the following address: or delete your account in the mobile application. Information about the possibility to unsubscribe is contained both in the application itself and on the DZI website  If you wish to request the deletion of the optional personal data provided by you, you can exercise your right by sending an email to the Data Protection Officer at the following address: As a result, the optional data provided by you will be deleted.


    Term for storage of personal data.

    In case you uninstall the Mobile application, the personal data provided by you will be stored for a period of 5 years from the date of uninstallation. 


    Recipients of personal data

    DZI employees from the business units have direct access to the personal data of the Users of the Mobile application, and they are directly responsible for managing the activities for its development and maintenance. DZI works with contractors and developers who support the functionalities of the Mobile application. Such contractors are, for example, SIRMA ICS JSC, DATICUM JSC and AKTA LTD, from which DZI requires compliance with the highest standards for technical and organizational support for the protection of personal data provided. DZI does not transfer data to countries other than Bulgaria.


    6. As a data subject, you have the following rights with regard to the processing of your personal data:

    ·        Right of access to your personal data and provision of information for the purposes of processing, categories of personal data, recipients to whom personal data are disclosed, retention periods, etc.

    ·        Right of correction - to request that your personal data be corrected if it is inaccurate or incomplete.

    ·        The right to withdraw your consent to the processing of your personal data at any time when the processing is carried out on the basis of your consent.

    ·        Right to be deleted (the “right to be forgotten”) - Your personal data should be deleted on the following grounds: personal data are no longer needed for the purposes for which they were collected/processed; when you deactivate and delete the application; when you withdraw your consent, when the processing of data is based on consent; where there is no other legal basis for processing; when the data have been processed illegally, etc.

    ·        The right to limit the processing for a certain period of time, when the accuracy of the data is disputed or there is an objection to the processing based on the legitimate interests of the controller.

    ·        Right to portability of personal data - to receive your personal data in a structured, widely used and machine-readable format, when they are processed in an automated manner on the basis of consent or contractual obligation, if there is a technical possibility to provide them.

    ·        The right to object to the processing of your personal data when their processing is based on the legitimate interest of the controller. In the event that your objection relates to the processing of personal data for direct marketing and customer relationship management, we will unconditionally suspend their processing for these purposes.

    ·        Right to appeal to the Commission for Personal Data Protection (CPDP) or to the court in connection with the processing of your personal data. You can get more information on the website of the Commission for Personal Data Protection:, where you can file a complaint.


    7. For all other issues related to the processing of personal data that are not regulated in these Rules, the provisions of Personal Data Protection Act and Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).


    8. Users may request information regarding the processing of personal data at any time in writing at the above address of the personal data controller or by email -


    Detailed information on the protection of personal data and the exercise of your rights can be found in the "Information on personal data protection" on our website


    IX.              Changes and fees.


    1. The services provided by kaksi generate the use of mobile data. The amount of data used can vary significantly depending on the frequency and duration of their use, as well as according to the conditions of the tariff plan used by a mobile operator. Significant charges for the use of mobile data may be charged by mobile operators in the absence of included mobile data in the tariff plan used by the User or in case of exceeding the monthly volume of mobile data according to the tariff plan. The terminology used above may vary from mobile service provider to provider.

    2. It is the obligation of the consumer to be aware of the terms of his/her contract with the mobile operator, including the circumstances that may lead to charging. Using the roaming service may result in an increase in charges.

    3. In case the User has doubts whether the use of mobile services would lead to charging or increase of his/her obligations, he/she should contact his mobile operator.

    4. kaksi shall not be liable for any fees, sanctions, taxes, surcharges or other charges imposed by the mobile operator as a result of the use of the mobile services.


    X.               Information and links from third parties.


    1. Mobile services shall provide access to links to third party websites and/or to information provided by third parties. kaksi and DZI - Life Insurance JSC are not responsible for the content of the third party - partners’ websites related to the application and/or the information in them, including without limitation to accuracy, compliance with copyright.


    2. kaksi is not responsible for any form of communication received from any linked site or platform, third party information or the ability to access such linked sites. The Mobile application provides such links and information for convenience only and the inclusion of any third party link or information does not imply endorsement by the Mobile application of such linked site or third party information.


    XI.              Intellectual property rights.


    The design, structure and content of the Mobile application are subject to copyright and the exclusive right to use them belongs to DZI - Life Insurance JSC. Users can print individual pages and/or parts, images (logos), graphics, etc. from the Mobile application, provided that they do not remove the identifying trademarks. Modification, copying, publication, sale or licensing of all or part of the Mobile application, as well as its use for other public or commercial purposes, is prohibited.


    XII.            Additional provisions.


    The provisions of the current legislation of the Republic of Bulgaria shall apply to the issues not settled by these Terms and Conditions.

    In cases of disputes between DZI - Life Insurance JSC and kaksi's Users which cannot be settled voluntarily, they are resolved in court by a competent Bulgarian court of justice.