Kindergarten Privacy Policy

Privacy Statement of “Private Kindergarten BRITANICA” Ltd.

I. PRIVACY POLICY

Focused on innovative approaches in the education and upbringing of children, “Private Kindergarten BRITANICA” Ltd. aims to develop creative thinking and to build confidence in defending one’s own ideas. Our goal is to form tomorrow’s leaders – people who can work in a team and find innovative solutions through non-standard critical thinking.

We are aware of our responsibilities and obligations when working with children and we respect all rights of children and their parents, especially the right to private and family life and the protection of their personal data.

“Private Kindergarten BRITANICA” Ltd. is a personal data controller and, in this capacity, complies with Regulation (EU) 2016/679, the Bulgarian Personal Data Protection Act and the other statutory and regulatory provisions in the field of personal data protection.

We process personal data lawfully, fairly and transparently. The data provided is collected only for specific, explicit and legitimate purposes and is not further processed in a manner incompatible with those purposes. The data we collect and store is minimised and limited only to what is necessary to fulfil the purposes for which it was collected. We make every effort within our organisation to keep the personal data of you and your children accurate and up to date. We do not store your data for longer than necessary for the purposes for which it is processed. Our priority is to ensure processing in a manner that provides an appropriate level of security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. We have implemented the necessary technical and organisational measures required by applicable law to protect and secure the personal data of our children and parents.

DEFINITIONS

“PERSONAL DATA” means any information relating to an identified natural person or a natural person who can be identified. Personal data includes name, personal identification number or foreigner identification number, e-mail address, telephone, postal address and similar information.

“PROCESSING” means any operation or set of operations performed on personal data or sets of personal data by automated or other means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making data available, alignment or combination, restriction, erasure or destruction.

This privacy policy presents the options available to you to access, update or otherwise exercise control over the personal data of you and your children. If you have questions about our practices or any of your rights described below, you may contact our team at: info@thecastle.bg. This mailbox is actively monitored.

II. WHAT PERSONAL DATA WE COLLECT

The personal data processed by “Private Kindergarten BRITANICA” Ltd. and the grounds for processing are:

1.1. Personal data of parents: name, personal identification number, identity card number, issuing authority and validity date, address, telephone and e-mail.

1.2. Personal data of children: name, personal identification number, address, gender, age and information about the child’s health condition. This information is collected only with the consent of the parents or guardians and is provided directly by them.

1.3. Personal data of persons who will bring or collect children from the kindergarten when parents are prevented from doing so. The names of these persons are declared in advance in writing by the parents. When a child is collected, our educators may check the identity card of the person in order to verify identity.

• Name, personal identification number and address of the child and parents are processed for the purpose of concluding an education contract with “Private Kindergarten BRITANICA” Ltd. Full names, personal identification numbers and addresses of parents and children are part of the minimum content of each contract. Without these personal data we cannot conclude a contract. Identity document data may also be processed in order to verify validity and prevent fraud or misuse of personal data.
• Data concerning gender and age of the child is collected in order to determine the most appropriate form, group, method and approach for education and care.
• Data concerning the child’s health condition, such as allergies or other specific illnesses, is processed to provide appropriate care, food and protection of the child during attendance.
• Name, telephone and e-mail are processed for communication with parents, identification of parents as potential or current clients, and provision of reports about the educational process and the development of the children.

1.4. Photos and videos of children and parents are processed only after explicit prior consent from the parents.

1.5. Video surveillance data on the territory of the kindergarten is processed in order to improve security, transparency of care and protection of children. In this case, processing is based on the protection of the life, health and legitimate interests of the children, parents and employees.

III. TRANSFER OF PERSONAL DATA

“Private Kindergarten BRITANICA” Ltd. does not share, sell, rent, trade or transfer personal information collected from the parents or guardians of children, except in the cases described below and where a lawful basis exists.

Personal data may be provided to service providers that assist us in providing education to children and organising sports camps, green school, ski week, excursions with organised transport and other activities. No provider may access personal data stored by “Private Kindergarten BRITANICA” Ltd. without first entering into confidentiality obligations that allow us to verify compliance. The collected personal information is transferred only to trusted partners with whom we organise and carry out the relevant activities and events for children. In accordance with the principle of data minimisation, these providers receive only the personal information they need to perform their functions.

Service providers are not allowed to retain the data for their own or independent purposes. Personal data may be shared with providers when explicit permission has been given, when necessary for performance of the contract or when required by law. Personal data may also be provided to public authorities where required by law. “Private Kindergarten BRITANICA” Ltd. does not transfer personal data to controllers or processors in countries outside the EU.

IV. PERIOD OF PROCESSING OF PERSONAL DATA BY “PRIVATE KINDERGARTEN BRITANICA” LTD.

We store your personal data for as long as necessary to fulfil the purposes described above. After that, if there is no consent or other lawful basis for further processing, the personal data will be deleted from our databases or destroyed in accordance with your instructions and wish to withdraw consent.

Personal data received in order to provide you with an offer is stored for the validity period of the offer or for the period for which you have explicitly consented. After the expiry of the offer or withdrawal of consent, “Private Kindergarten BRITANICA” Ltd. will delete and destroy all data without undue delay or anonymise it. Personal data provided in connection with a contract concluded with us is stored for five years after performance of the contract for protection of legal interests in judicial or administrative disputes, while accounting documents are stored for the statutory period.

We will notify you if the storage period must be extended due to a legal obligation, legitimate interests of the controller or another lawful reason.

V. YOUR RIGHTS REGARDING THE PERSONAL DATA PROVIDED

1. Right to information. You may request information at any time about whether your personal data is stored, the purposes of processing, the categories of data processed, recipients to whom it has been disclosed, the intended storage period and whether automated decision-making or profiling exists.

2. Right to withdrawal. If you have given consent for the use of your data, you may withdraw it at any time with future effect, without stating reasons. Your request may be sent to team@borche.org.

3. Right to rectification. If you discover that data stored by us is inaccurate, you may contact us so that we can correct it.

4. Right to erasure. You may request that we delete your data without undue delay. We will delete it within a reasonable period once we confirm that there are no other grounds requiring processing or storage.

5. Right to restriction of processing. In certain cases, such as where you contest the accuracy of the data or the grounds for storage are being checked, you may request restriction of processing. During restriction, we may only store the data, and other processing is possible only with your consent.

6. Right to data portability. Upon your request, we will provide or transfer the data to you or another controller in a structured, commonly used and machine-readable format, where technically feasible.

7. Right to object. You may object at any time to processing for direct marketing, including profiling, and in cases where processing is based on a task in the public interest or our legitimate interests.

8. Right not to be subject to a decision based solely on automated processing, including profiling.

9. Right to lodge a complaint. You may lodge a complaint with the competent supervisory authority, in Bulgaria the Commission for Personal Data Protection or the court, if you believe your rights have been violated.

Commission for Personal Data Protection

Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Information and Contact Centre: 02/91-53-518

E-mail: kzld@cpdp.bg

Website: www.cpdp.bg

Contacts of “Private Kindergarten BRITANICA” Ltd. and details of the responsible Data Protection Officer:

Geo Milev address: Sofia 1574, Geo Milev district, 47 Edison St., near the park. Tel. +359 2 488 78 77, +359 895 66 54 98. E-mail: info@thecastle.bg

Dragalevtsi address: Sofia, Dragalevtsi district, 27 Momino Venche St. Tel. +359 2 488 78 77, +359 899 99 52 55. E-mail: info@britanica-parkschool.bg

Please note that when you contact us through the above e-mail addresses, the data you provide, such as your e-mail, and possibly your name and telephone number, is processed by us in order to answer your questions and resolve the issue raised. We undertake to delete the data stored in this connection once processing is no longer necessary, or to restrict processing if legal retention obligations exist.