Privacy and Data Protection Policy

SmartyKids has a policy of protecting the rights and privacy of any individual that come into contact with the company and share personal information.

In order to benefit from services, platforms and products offered by SmartyKids you may have to complete a registration procedure or to provide personal information to SmartyKids.

Registration may be required in order to provide you with access to specific functionality on our website or for your participation in promotional events.

The Data Protection Policy describes the personal data that we collect and the specific ways we utilize your data in accordance with the regulations of the European Union. Please, read carefully the following Privacy Policy terms and, if necessary, submit your questions.

This Data Protection Policy regulates the relations between SmartyKids and the individuals and/or corporate entities (referred to as Users) with regards to collection, storage, usage and protection of personal data provided by the Users. Subject to the Data Protection Policy is any information that SmartyKids and the authorized by the company individuals acting on behalf of SmartyKids, may obtain for the User while using a product of SmartyKids.

1. Personal data collected and processed by SmartyKids

In the present Data Protection Policy the term personal data refers to the following:

1. 1. The information (including but not limited to personal data) provided voluntarily by the User to SmartyKids in the process of registration in order to use a product of SmartyKids (including the account activation upon first login) or throughout the term of usage of the products (incl. account creation, contact with the support department, etc.). The information is provided by filling out the forms by the User where the information in the non-obligatory form fields is provided voluntarily by the User. User Data is any information filled out by the User directly or provided to a SmartyKids representative in the way determined for the different products of SmartyKids.

0. 2. Other information for the User that SmartyKids obtains as described in Part 2 of the present Data Protection Policy.

2. Purpose of User Data collection and use

The information we collect, store and process as per Part 1 of this Data Protection Policy serves solely the following purposes:

2.1. Identification of the User while performing activities on SmartyKids and utilizing its products;

2.2. In order to offer personalized visits report (inclusively, for personalizing services for the User) and for user activity report SmartyKids uses Cookies.

2.3. To interact with the User in the terms of the agreement between the User and SmartyKids.

2.4. Statistical and other analysis based on anonymous data (including User’s position on using products/services provided by SmartyKids).

2.5. To inform and update the User on new products or to provide other important to the User information.

3. Terms of processing and disclosure of personal data

1. 1. Storage (incl. change and deletion) of User’s personal data is performed in accordance with the functionality of specific SmartyKids products, the supporting information to those, as well as the agreement on their usage.

3. 2. Disclosure of personal data to third parties is possible solely in the following cases:

1. 1. 1. The User has agreed to the disclosure in advance.
      2. The personal data disclosure is required for execution of agreement in which the User acts as one of the Parties or initiated by the User.
      3. The disclosure is required for protection of rights of SmartyKids or third parties in case the User breaks the intellectual property rights of SmartyKids and/or the respective license agreement.
      4. Disclosure of personal data is required following legal procedures, court decision or government or other legal authorities act, whereas the disclosure will be performed in accordance with the applicable law.
      5. In processing personal data of Users SmartyKids follows strictly the General Data Protection Regulation of the European Union (GDPR).

4. Personal data storage term

Your personal data is stored for as long as necessary to process the correspondence, to personalize your experience and any additional actions. For advertising messages personal data is stored for 5 years or until withdrawal of consent. The information collected through the User account is kept until the deactivation of the account, unless longer storage is necessary for the needs of the subsequent financial and accounting control. In this case, the terms of storage of accounting documentation apply.

5. Limitations of liability

5.1. SmartyKids does not initiate the publication of personal information when using SmartyKids products, does not control its authenticity and accuracy, while SmartyKids reserves the right to request confirmation by the User on the accuracy of the information provided.

5.2. When filling in (providing to SmartyKids) personal data of third parties, the User guarantees that all necessary permissions and consent for these actions are obtained by the User, and also guarantees full and unconditional consent of these third parties to all provisions of this Data Protection Policy.

6. Personal data protection

SmartyKids undertakes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from illegal or accidental access to it, destruction, alteration, blocking, copying, providing, disseminating personal information, as well as other illegal actions related to disclosure of personal information, whereas protection includes:

• Protection of allowed sessions

• Continuously improvements on the ways data is collected, stored and processed.

Our websites does not store information about your debit and credit cards. It is the user’s obligation to protect the confidentiality of the username and password provided by SmartyKids. Each order placed online will be considered regular by SmartyKids if it uses a username and password that the system has accepted as valid, regardless of whether they are used by a person other than the holder or by an unauthorized person.

7. User rights

In accordance with the applicable provisions, the Users have the following rights:

1. 1. Right of correction: when the User considers that their personal data is inaccurate or incomplete, they may request such personal data to be changed accordingly;
   2. Right of deletion: the User can request the deletion of their personal data, as far as this is allowed by the applicable law;
   3. Right of restriction: the User may request a restriction on the processing of their personal data, unless this would be in contradiction to our legal obligations;
   4. Right of objection: the User can object to the processing of their personal data on grounds related to their specific situation;
   5. Right of consent withdrawal: when the User has given their consent to the processing of their personal data, they have the right to withdraw this consent at any time. Withdrawal of consent does not interfere with the legal grounds of processing of the User’s data on the basis of the consent given by them prior withdrawal and with processing of data based on another legal basis;
   6. Personal choice: the User has the right to refuse to provide their personal information, which may lead to a refusal to submit an offer and/or use SmartyKids products.

8. Final provisions

This Personal Data Protection Policy may be changed unilaterally by SmartyKids by posting their latest version on smarty-kids.eu and/or universe.smarty-kids.eu. In case of non-compliance in the Data Protection Policy with the provisions of the License Agreement with the User, the advantage has the License Agreement.

9. Contact at SmartyKids

In case you have questions related to the Personal Data Protection Policy at www.smarty-kids.eu and universe.smarty-kids.eu, the collection and processing of your personal data during their use, you can write to us at the following email address: hello@smarty-kids.bg.

The administrator of your personal data is: SmartyKids Bulgaria Ltd., address: 59, Yan Huniyadi blvd., floor 3, Varna 9000, Bulgaria, e-mail address: hello@smarty-kids.bg.

In case of violation of the user rights, in accordance with the above or with the applicable law for protection of personal data, you have the right to contact the authorities as follows:

Personal Data Protection Commission

Address for correspondence: 2, Prof. Tsvetan Lazarov Street, Sofia 1592, Bulgaria, EU.

+359 2 915 3 518

www.срdр.bg