of the Be-self Platform (mobile application BE-SELF)
created by the team of BE-Self Project Building Strong Foundations: A European Partnership for Preschoolers’ Social and Emotional Skills Development 2024-1-BG01-KA220 SCH-000246610 and operated by
the New Bulgarian University
Project Manager and General Coordinator:
Nadia Koltcheva, Ph.D.
New Bulgarian University
Department of Cognitive Science and Psychology
21, Montevideo, blvd.
1618, Sofia
Bulgaria
Email: be-self@nbu.bg
Introduction
These privacy policies describe our internal practices in storing and processing information that may be used to directly or indirectly identify an individual ("Personal Data"). We encourage you to familiarize yourself with the full content of this document, and for questions about these policies, the way we handle your data or the need for information on how to exercise your rights with respect to your personal information, you may always contact us to E-mail: be-self@nbu.bg
1. General information.
The measures and means of protection of personal data collected, processed, stored and provided by New Bulgarian University as a personal data controller approved in Instruction, prepared in accordance with the provisions of the Personal Data Protection Act (LPPD), Ordinance on the minimum level technical and organizational measures and the permissible type of protection of personal data and Regulation 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data.
Basic Principles in the Processing of Personal Data:
When collecting and processing your personal data, we are guided entirely by the principles of legality, integrity and transparency, the relevance of data processing to the relevant objectives, the accuracy and timeliness of the data processed. The following personal data are collected and processed for the purpose of concluding contracts for the services we provide and the fulfillment of the obligations assumed under them, as well as for the fulfillment of statutory obligations.
The provision of your personal data is entirely voluntary. Refusing to provide them has no unwanted consequences for you. However, Be-self (New Bulgarian University) needs some types of personal data in order to provide access to the mobile application, service delivery, quality performance of our duties, as well as contact with you if necessary.
Upon future changes to these policies, we will notify you in good time. By continuing to use our services after the changes are introduced, you are agreeing to the new privacy policy.
2. The information we collect. Time frames, purposes and legal basis for processing your personal data.
Accessing the mobile application requires creating an account with an email (email address), and password. These personal data are stored encrypted, separately and independently of each other on a Google-owned server, and we have access to your names and e-mail address that you entered upon registration. Your email address can be used to restore access, customer and technical support, and notifications.
For the purposes of our educational activity, we may collect, store and process the following types of personal data:
• contact details (names, e-mail);
• nationality;
• jobs and education;
To improve personal data security, control your access to your application account, and prevent data misuse, your device's IP address is automatically saved and stored for several weeks on a Google server. When you take actions to remove your app account, all available information is deleted by the system and servers within 180 days.
The processing of your personal data is done with the purpose:
- In order to be able to use all the services we offer;
- To get quality service in the shortest possible time;
- To ensure honesty, fairness and prevent fraud;
- In order to contact you in relation to requested products;
- To send you up-to-date information about Be-self;
How do we protect your personal data:
In order to ensure the adequate protection of your personal data, we apply all the necessary organizational and technical measures provided for in Regulation 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 and the Personal Data Protection Act in the Republic of Bulgaria. For the sake of maximum security when processing, transferring and storing your data, we also use additional protection mechanisms such as encryption, pseudonymisation, etc., depending on the specific case.
Term of storage of your personal data:
In addition to the specific cases listed above, the length of time that your personal data are stored depends on the purposes of their processing, and your use of your personal data will generally cease by terminating our contractual relationship. However, your personal data is not deleted directly but is retained with a view to finalizing all financial obligations and the expiry of the statutory data storage obligations, such as the data storage and processing obligations under the Accountancy Act (11 years); the expiry of the limitation periods laid down in the Law on Obligations and Contracts (5 years); the expiry of the time limits for providing information to the court, the competent state authorities, as well as other grounds provided by the current legislation (5 years).
In view of the aforementioned maintenance of your awareness of the services we offer, we continue to store and use your email address solely for that purpose and based on your consent to that effect.
Personal Data Administrator New Bulgarian University collects, stores and processes your personal data on one of the above-mentioned grounds by providing the same to the personal data processors who, on the basis of a contract with us, process your personal data on our behalf by having a direct / indirect access to your personal information:
- companies providing accounting advisory services for the correct and accurate keeping of our accounts;
- courier companies - when sending a specified address to the products listed in the appendix;
- insurance companies - in view of the qualitative performance of the services under the contract, where our insurance obligations include insurance;
- besides the above mentioned cases, your personal data can be shared with officials according to Bulgarian and European legislation or court decision.
3. Your rights in relation to the processing of your personal data.
- Right to access your personal data:
You have the right to request and receive the following information:
- whether we are processing any data that is relevant to you;
- what are the purposes of processing, what are the categories of personal data we process, which recipients or categories of recipients we disclose the data we collect.
The above information is provided in an understandable form, indicating your personal data being processed, as well as any available information about its source.
- Right of rectification: You may at any time request to correct incomplete or inaccurate personal data.
- Right to delete (right to be forgotten):
Where any of the following grounds apply, you may request that your personal data be deleted in the event that:
- your personal data is no longer necessary for the purposes for which it was collected or processed;
- your personal data is being processed unlawfully.
- Right to Restrict Processing:
You may want to restrict the processing of your customizable data in case you dispute the correctness of the data. In such a dispute, the use of your data is suspended for the period of time that its accuracy has to be verified.
- Right to judicial and administrative protection:
If you believe that we are in any way violating the applicable legal framework, please contact us (be-self@nbu.bg to clarify the issue. Of course, you always have the right to file a relevant complaint with the Personal Data Protection Commission at: https://www.cpdp.bg
Under the terms of the General Data Protection Regulation (Regulation (EC) 2016/679), you must have the necessary age to consent to the processing of personal data. If you are under the age of 16 and want to use our services, keep in mind that the processing of personal data is lawful only if and to the extent that such consent is given in writing or authorized by the parent's responsibility to you.