PRIVACYBELEID VAN DE PROGRAMMEERCLUB "MINDHUB"

  1. Summary of the Privacy Policy


    When you use the products and services of MindHub BG EOOD (MindHub), you entrust us with your information. This Privacy Policy aims at helping you understand what data we collect, why we collect it and what we do with it. We hope you will take your time to read it thoroughly since its content is important. MindHub takes care of your privacy. Therefore we collect and use personal data only because we need it to provide you with MindHub products, services and website (jointly “MindHub Services”). Pursuant to the Data Protection Act of 1998, the EU General Data Protection Regulation (GDPR) approved by the European parliament on 14 April 2016 and acts associated therewith, we are legally bound to protect the personal data we collect from you. 
    Your personal data includes information such as: 
    Name, phone number, e-mail, name and date of birth of the child you enroll in MindHub, e-mail, and other collected data that could identify you directly or indirectly. 

    Our policy also describes the options we provide you with to gain access, to update or otherwise control your personal data we process. If you have questions regarding our practice or any of our rights specified hereunder, you can get in touch with our data protection officer (DPO) and our team by contacting us at privacy@mindhub.bg. This mailbox is actively monitored and managed.

    II. What information we collect
    1. Information you present to us
    1.1 Information required to use MindHub Services.

    We require and collect the following personal data for you when you use MindHub Services. This information is necessary for the proper performance of our contract and allows us to comply with our legal obligations. Without it, we might not be able to provide you with all the requested services.
    Account information. When you register at MindHub website, we require certain information, such as:
    1/ Name and Surname: To be able to address the client personally, and for us to make sure everybody is a unique client and does not use fake registrations.

    2/ E-mail:

    - the e-mail address enables the client to log in to their account and change their data as well as to track their payments, selected classes and to receive access to extra services such as weekly update for parents, neurological information about the child’s age etc. 
    - the e-mail address enables us and our representatives to inform the parent about upcoming events related to the learning process in MindHub, starting a new term, possible cancellation of classes or change of the time for a class, urgencies such as illness of a mentor, quarantine due to an illness as well as other force majeure circumstances

    - the e-mail address enables us to inform parents about upcoming opportunities for early enrolment and discounts, and generally any useful information about the learning process in MindHub as well as to inform them about upcoming events and seminars we organize. 
    - all these messages (requiring e-mail address) directly associated with the service provision can also be sent over Facebook.
    3/ City: to suggest the closest centre to the user
    4/ Phone number: it is necessary to inform the client about a change of classes, cancellation, to send urgent messages and information about enrollment for a new term, and if eligible for discounts, to be able to use this information on time
    5/ How did you learn about MindHub? This information is necessary to measure the efficiency and improve our service as well as to target better our communication messages to our clients.
    6/ Name of a child: to be able to call the child by their name in class. Our service is group yet personalized and it is important to help children get used to recognizing their name from an early age; also, if the client has enrolled more than one child, we have to distinguish them.
    7/ Date of birth of a child: this information is of extreme importance for the selection of MindHub level. Since levels are based on children’s age, it is not possible to select the proper level without having the date of birth.

    1.2 Information that you decide whether to give us
    You can choose whether to provide us with additional personal information for a better experience with MindHub Services.
    This additional information will be processed based on your consent.

    • Marketing consent for receipt of information over e-mail, Push notifications, Facebook and/or SMS.

    • Consent for making and using photos - you can give us your consent to make photos and videos of you and your child intended for marketing, advertising or training purposes.

    • Other information - you can decide to provide us with other information when submitting forms, participate in studies, polls and promotions, when you update or provide new information for your MindHub parental account, or when you use other options of MindHub services.
    1.3 Information required to use payment services

    Data process officer has to collect the following information since it is required for the proper performance of our contract. He is obliged to comply with the current legislation (e.g. anti-money laundering rules). Unless you provide this information, you will not be able to use the Payment services and MindHub Services as they have to be paid before you attend a class.


Payment information. To use certain functions of MindHub Services (such as reservation or purchase), we may require you to provide certain financial information (such as bank account or credit card) to facilitate payment processing (we use a third party provider for the payments, such as ePay).

  1. Information we collect automatically from your use of MindHub Services and payment services
When you use MindHub Services and payment services, we collect automatic information including personal data about the services you use and how you use them. This information is necessary for the proper performance of our contract and allows us to comply with our legal obligations and to provide and improve functionality of the platform and MindHub Services.

This information includes, among others: details on how you have used MindHub Services, IP address, dates and time of access, information on hardware and software, information on device, information on device events, unique identifiers, crash data, “cookies” data of pages you have visited before or after using MindHub Services.
Cookies and similar technologies. We use “cookies” and other similar technologies. We can also allow our business partners to use these technologies to track MindHub Services or to engage others to track your behaviour on our behalf. For more information on the use of these technologies, please check our Cookie Policy.



  1. Information we collect from third parties

MindHub can collect information including personal data about you by third party while using the MindHub platform and payment services as well as to obtain information from other sources and to combine it with information we collect through MindHub Services and payment services. We do not control and are not responsible of how third parties presenting your information process your personal data and any request for information on disclosing your personal information must be addressed to such third parties.


Other sources. To the extent permitted by the applicable law we can receive additional information about you, such as demographic data or information on fraud detection by suppliers and / or third-party partners and to combine it with the information we have about you.

III. How we use the information

We strive to minimize the data we collect and limit its use to (1) data we have received permission for, (2) as required for the Service provision we are obliged to provide, or (3) since we may use them for the purpose of lawfulness or for other legal purposes. These uses cover: 

Provision, improvement, updating and enhancement of MindHub Services and Services we provide to you. We collect various data related to your use and / or interaction with MindHub Services. 

We use this information for:

ØImprovement and optimization of application and provision of our MindHub Services


ØDiagnosing problems and identifying risks, mistakes or required improvements in the security of MindHub Services

ØCollecting aggregated statistics on the use of MindHub Services

ØFor us to understand the way you use MindHub Services and what products and services are most suitable for you.


Often much of the collected data is aggregated or statistical data on how individuals use MindHub Services and is not related to any personal data; however, it is personal data by its nature or is related to personal data, respectively. 

Sharing with trusted third parties. We can share your personal data with companies that represent us for the relevant MindHub centre, affiliates of our corporate family, third parties we have partnered with to let you integrate their services into our MindHub software system, and with trusted third-party service providers when this data is necessary to provide services on our behalf, such as:

ØCredit card payment processing,

ØConducting of competitions and surveys,

ØCommunication with you such as over e-mail, or service provision,

ØAnalysis of demographic data of our services and clients.

 

We share your personal data only if this is necessary for the provision of a third-party service and this third party requires your data to provide the service on our behalf. These third parties (and all subcontractors) follow strict requirements for data processing and are prohibited from sharing your personal data for other purposes unless they obtain your consent for this.

Which are the organizations associated with MindHub that will provide you services and will have access to your data: MindHub BG EOOD, its franchisees and representatives in the centre of your choice. Example: When a client registers on MindHub website and selects MindHub Plovdiv, his (her) data will be accessed by MindHub BG EOOD as a carrier of rights for Bulgaria, and by the company that carries the rights for MindHub Plovdiv.

The IT company that services MindHub hosting may also have access to your data.


Communication with you.
We can contact you directly or through a third-party service provider with regards to products or services you have registered as purchased from us such as those required for communication, payment transactions or services. We can also contact you with offers for extra services we believe you will consider valuable if you give us your consent to do so or where this is permitted based on legitimate grounds. Your consent to use our services is not necessary. These contacts may include:

Øe-mail,

Øtext messages (SMS),

Øphone calls,

Ømobile application notifications


If we collect information from you regarding a co-branded proposal, it will be clear at the moment of collection who collects the information and whose privacy notice applies. Moreover, this proposal will list all selection options regarding the use and / or sharing of your personal data with a partner that we use a joint brand or conduct a joint campaign.
If you would like that your personal information be removed from our database, kindly contact us at privacy@mindhub.bg.


Transfer of personal data abroad. Please note that the information collected by MindHub will be stored within the European Union which may have data protection laws that differ from those in your country of residence. By installing and using MindHub Services, you agree to the storing and processing of this information within the European Union. If you use our services from a country other than the country of our servers, your communication with us may result in your personal data being transferred across international borders. Also, when you call us or initiate a call we can provide you with support from one of our global location outside your country of origin. In such cases your personal data will be processed in accordance with this Privacy Notice. 

Website analysis. We use several tools for web analysis provided by partners such as Google Analytics to collect information of the way you interact with our website and mobile application including pages you visit, which website you have visited before visiting our website, how much time you spend on each page, what operation system and web browser you use and IP information. We use the information provided by these tools to improve our services. These tools place permanent “cookies” in your browser to identify you as a unique user when you visit our website next time. “Cookies” cannot be used by anyone else but the service provider (e.g. Google for Google Analytics). The information collected by the “cookies” can be delivered and stored by these service partners on servers in a country other than your country of residence. Although the information collected does not include personal data such as name, address, payment information etc., the information collected is used and shared by the service provider in accordance with their individual privacy policy.

You can control the technologies we use by managing the settings through our Cookie Policy or “banners with cookies” that may be presented (depending on the URL of the visited website) when you visit our web pages for the first time or by using the settings in your browser or third-party tools.


 

Third-party websites. Our website and our mobile applications contain links to third-party websites. We bear no responsibility for the privacy policy or the content of third-party websites. Please, read the Privacy Notice of every website you visit.

  1. Accessing, updating or deleting your data

For easier access, review, update or deletion of personal data (if any) or for update of your subscription preferences, please log in to your MindHub account and change the data you want to change. Alternatively, if you want your data do be deleted, you can contact us by one of the methods specified in the Contacts section below and we will remove your personal data from our servers within 30 (thirty) days at the latest.

  1. Storing and protecting your data

We follow general standards for storing and protection of personal data we collect and we do so for all processes of receipt and storage of this data using an encryption where necessary. We store personal data only for as long as necessary to provide the services you have requested and then for various legitimate legal or business purposes. For any questions regarding security or privacy of your personal data, you can contact us at privacy@mindhub.bg.

  1. Transfer in the event of theft or change of control.

We can transfer information including your personal data in connection with a merger, sale, reorganization, acquisition or other change of ownership or control of or over MindHub BG EOOD or any other affiliates (in any case whether in whole or in part). Should any of these events arise, we shall engage ourselves to inform users before their information is no longer subject to the Privacy Policy and practice of MindHub BG EOOD in its current structure.

VII. Changes to our Privacy Notice

We reserve the right to change our Privacy Notice at any time. Should we decide to amend our Privacy Notice, we shall post these amendments to this Privacy Notice and any other places we deem appropriate for you to know what information we collect, how we use it and under what circumstances, if any, we disclose it. Should we make substantial changes to this Privacy Notice, we shall inform you here, over e-mail or by notice on our Home Page not less than thirty days before the changes take place.

VIII. Contact us

If you have questions, worries or complaints about our Privacy Notice, our practice or Services, you can contact our Privacy Department at prvacy@mindhub.bg.

Last update: 24.05.2018