Privacy Policy

My Kids Academy (My Kids Academy or the Company) is committed to protecting the privacy and security of your personal information by applying all appropriate technical and organizational measures to prevent the unauthorized or unlawful processing, accidental loss, destruction or premature deletion of information. This Policy has been prepared and is based on the National and European legislation in the field of personal data protection. This privacy notice aims to give you information on how My Kids Academy collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, contact us by email, telephone or by post.

 The privacy policy applies to My Kids Academy's devices, websites, online programs, services and marketing activities that refer or link to the privacy policy (collectively, our "Services"). Please note that the privacy policy applies regardless of whether you are using a computer, mobile phone, tablet, or other device to access our services. My Kids Academy may, through notices or otherwise, in addition to this privacy policy, provide more information in connection with specific products and / or services. The information and terms you receive in this case only apply to your use of the services that the specific message or information refer to.

Please read carefully this Privacy Policy before using the Website or providing your personal information. By using our services you agree how My Kids Academy collects, uses, shares, transfers and stores your information. You will always find the latest version of the policy on the website.

Contact details:

Full name of legal entity: My Kids Academy Ltd

Postal address: 9 Rostok Street, Varna 9010

Web site: www.wandering.help

Е-mail: gdpr@wandering.help

Supervisory authority for data protection issues:

Full name of legal entity: Commission for personal data protection

Postal address:  2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

Web site: www.cpdp.bg 

Е-mail: kzld@cpdp.bg

 „Personal information“ is information that can be used directly or indirectly to identify or contact an individual. For example, you can be identified by your name, address, and phone number, but you can sometimes also be identified by providing information about your family or similar information. Personal information may also be information about your health. Information about your health is considered sensitive and is therefore treated with more care.

„Processing“ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

„Restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

▪ Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

▪  Contact Data includes billing address, delivery address, email address and telephone numbers for yourself, your next of kin, access contacts and medical parties.

▪ Financial Data includes bank account and payment card details.

▪ Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

▪ Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

▪ Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.

▪ Usage Data includes information about how you use our website, products and services.

▪ Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

▪ Health Data includes existing medical conditions, medication prescriptions, general practitioner details, carer details and other medical information.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Through some of our services, you can share content or communicate with family and friends. My Kids Academy can collect information you provide about these persons such as name, address, email or phone number. The data and the communication is stored in our system to view the message history

We collect some categories of Special Categories of Personal Data, such as that found within Health Data, and will only process this data where you have provided us with explicit informed consent as part of the product and services which we provide to you or when we have a contract with you. We do not collect the other categories of Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions or trade union membership). Nor do we collect any information about criminal convictions and offences.

If you call a call to our emergency centre, the call is automatically recorded and stored in our system for My Kids Academy to follow your health history according to the service we offer.

Children’s privacy - My Kids Academy does not knowingly solicit or collect personal data from or about children (aged 18 and under) without the consent of a parent or guardian, and My Kids Academy does not knowingly market its products or services to children. If My Kids Academy becomes aware that the person submitting personal data, through any part of My Kids Academy’s websites, is a child, My Kids Academy will use reasonable efforts to delete that personal data from its files as soon as possible. My Kids Academy will also use reasonable efforts to ensure that this personal data is not used for any purpose, nor disclosed to any third party. As My Kids Academy does not seek to collect any personal data about children, and My Kids Academy deletes any data collected inadvertently as soon as it is discovered, My Kids Academy retains no data about children that could be reviewed or deleted. If a guardian requests review or deletion of data about their child before My Kids Academy has discovered and deleted the data, then My Kids Academy will of course honor that request.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Health and Financial Data by filling in forms or by corresponding with us by post, phone, email, verbally or otherwise. This includes personal data you provide when you:

▪ apply for our products or services;

▪  filling out our information questionnaire in relation to the products or services;

▪ subscribe to our service or publications;

▪ request marketing to be sent to you;

▪ enter a competition, promotion or survey; or

▪ give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

▪ Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks based inside OR outside the EU; and
• search information providers such based inside OR outside the EU.

▪ Identity and Contact Data from publicly availably sources based inside the EU.

▪ Identity, Health and Contact Data from emergency services, local authorities and care agencies based inside the EU.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Marketing - We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us - We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. We will get your express opt-in consent before we share your personal data with any external companies for marketing purposes.

Opting out - You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies - You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

Change of purpose - We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 6 months.

To process your personal data, we rely on the following legal bases:

▪ compliance with a legal obligation;

▪ performance of a contract;

▪ for the purposes of our legitimate interests, which take precedence over the interests of data subjects;

▪ based on your consent.

The processing of sensitive personal data is based on one of the following legal bases:

▪ when executing a contract with a client to provide a service;

▪ your explicit consent;

▪ processing is necessary to fulfill the rights and obligations of the Company as an employer and the related rights of the data subjects;

▪ processing is necessary to protect the vital interests of the data subject or that of another person;

▪ processing is necessary to establish, enforce or defend legal claims.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

My Kids Academy takes reasonable steps to ensure that we only keep information about you for as long as it is necessary to fulfil the purposes for which they were collected or the storage is required to comply with statutory legal obligations.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As a rule, we discontinue using your personal information, for the purposes, related to the contractual relationship, after termination of the contract, but we do not delete them before all financial obligations  are finally settled and the expiry of statutory data storage - storage and processing of accounting data, expiry of limitation periods for filing claims, obligations to provide information to the court and competent state bodies, etc.

Some of the data may be anonymized. Data anonymization is an alternative of data deletion and can  be defined as a process by which personal data is irreversibly altered in such a way that a data subject can no longer be identified directly or indirectly.

My Kids Academy shares your personal information only when necessary to provide a product, improve a service, or fulfil an agreement. Third parties may not access your information for marketing or business purposes without your consent. The Comnany takes the necessary measures to protect the rights and interests of the data subjects, including  making explicit contractual obligations on the processing of personal data to guarantee the security of the data and safeguard their confidentiality.

 My Kids Academy may, if necessary, share your information with:

▪ Companies and persons acting as data processors or co-administrators who provide services for the benefit of the My Kids Academy's business activities, such as an accounting firm, a law firm, auditors for the needs of the relevant audits, insurers, etc .;

▪ Companies and individuals, which by award maintain equipment, software and hardware used for processing personal data and necessary for building the company network and for performing various reporting, payment for services and products, technical support, sending email, etc .;

▪ Banks and banking institutions in connection with the processing of payments;

▪ Bodies, institutions and persons to whom we are obliged to provide personal data under the current legislationMy Kids Academy may in some cases have a legal obligation to disclose personal information about you to the authorities. This may be the case if there is a court decision, if it is necessary with regard to national security, to maintain law and order, if it is in the public interest or if it is necessary to protect our business and other users.

▪ Public bodies, such as general practitioners and the emergency services, as may be required as part of the services we provide.

▪ Postal operators and transport/courier companies, with a view to sending consignments containing contracts, supplementary agreements, other documents or products and the need to verify their identity upon delivery;

▪ In the event that we are acquired by another company and some or all of our assets are transferred to the acquiring company or as part of a bankruptcy procedure, merger or reorganization. 

My Kids Academy does not transfer your information outside the EU or the European Economic Area (EEA), so-called third countries, unless the transfer can be made in accordance with applicable law:

▪ The European Commission has adopted a decision confirming that the country to which the transfer is being carried out provides an adequate level of protection for the data subjects' rights and freedoms;

▪ There are appropriate protection measures - such as Binding Corporate Rules, standard contract terms, approved by the European Commission, approved code of conduct or a certification mechanism;

▪ The data subject has given explicit consent to the transfer after being informed of the possible risks, or

▪ Transfer is required for one of the purposes listed in the GDPR, including contract performance with the subject, protecting the public interest, the establishment and defense of legal disputes, protection of the vital interests of the data subject in cases where he or she is physically or legally incapable of giving consent.

 My Kids Academy ensures that your personal information is secure by communicating our privacy and security guidelines to all our employees and maintains a high level of security throughout the company. We take both physical and technical measures to protect the personal data we treat process.  Some of them include, but are not limited to: authentication, access control, workstation security, internal network security, data transmission control, information encryption (if is necessary), and more. Furthermore, your information is stored on computer systems housed in limited access facilities using physical security measures. The Company has established the requirements for the processing, registration and storage of personal data by internal procedures. Their compliance is monitored inseparable. However, please note that no webpage, internet transfer, computer system or wireless connection is completely secure. We are also not responsible for information you provide in chat forums or social media, so think about what information you choose to share in these cases.

Detailed and comprehensive information on your rights as data subjects can be found in the text of Regulation (EU) 2016/679 (GDPR).

In the next lines will be affected the main aspects of their occurrence and the way you can exercise them.

▪ Right of access to personal data (Art. 15 GDPR) - You can ask us to confirm whether personal information about you is being processed by us. If such processing has taken place, you can request the access to the data. You are entitled to know what information My Kids Academy processes relating to you, how we collect it, if we have shared it with someone else and how long we intend to save it.  ;

▪  Right to correction (Art. 16 GDPR) - if you find inaccuracies or need to update your personal data, you can ask the Company to correct it without undue delay;

▪ Right to erasure / “right to be forgotten” (Art. 17 GDPR) - You can ask us to delete the personal data concerning you immediately and we are obliged to delete it if one of the following reasons applies:

 (1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.

(3) You file an objection against the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 GDPR.

(4) The personal data concerning you have been processed unlawfully.

(5) The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which we are subject.

(6) The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.

If we have made the personal data concerning you public and we are obliged to delete it pursuant to Art. 17 para. 1 GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform those responsible for data processing who process the personal data that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.

Exemptions - The right to cancellation does not exist insofar as the processing is necessary:

(1) to exercise freedom of expression and information;

(2) to fulfil a legal obligation required for processing under the law of the Union or of the Member States to which we are subject, or to perform a task in the public interest or in the exercise of official authority conferred on us;

(3) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the law referred to under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or

(5) to assert, exercise or defend legal claims.

▪ Right to limitation of processing (Art. 18 GDPR) - under the following conditions, you may request that the processing of personal data concerning you be restricted:

(1) if you dispute the accuracy of the personal data concerning you for a period that enables us to verify the accuracy of the personal data;

(2) the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;

(3) we no longer need the personal data for the purposes of processing, but you do need them to assert, exercise or defend legal claims, or

(4) if you have filed an objection to the processing pursuant to Art. 21 para. 1 GDPR and it is not yet clear whether our justified reasons outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the European Union or a Member State.

If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by us before the restriction is lifted.

▪ Right to data portability (Art. 20 GDPR) - You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another controller in charge without obstruction by the controller in charge to whom the personal data was provided, where:

(1) processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and

(2) processing is carried out by means of automated methods.

In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one data controller to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

▪ Right to objection (Art. 21 GDPR) - You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you under Article 6(1)(e) or (f) of the GDPR, including profiling based on these provisions.

We will no longer process personal data relating to you unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

▪ Automated individual decision-making, including profiling (Art. 22 GDPR) - The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Shall not apply if the decision:

• is necessary for entering into, or performance of, a contract between the data subject and a data controller;
• measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
• is based on the data subject’s explicit consent

▪ Right to withdraw your consent - You have the right to revoke a consent you have given. My Kids Academy will then cease processing the current information if there is no other legal basis which entitles us to continue the processing. We will inform you accordingly.

▪ Right of appeal to a supervisory authority (Art. 77 GDPR) - Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or suspect of infringement, if you believe that the processing of personal data concerning you is contrary to the GDPR.

Just as we undertake a number of obligations and take a wide range of technical and organizational measures to ensure the confidentiality of your personal data, you are under the obligation to provide us with accurate, true and non-misleading information, the sharing of which does not infringe the rights to any third party.

In order to implement the most current measures to protect and comply with applicable law, we will update this Privacy Policy on a regular basis. When this happens, the revised policy will be published on this Website with a new date “Last Modified” and will be effective from the date of publication. We invite you to review the current version of this Privacy Policy regularly to make sure you are aware of any changes.