This privacy policy has been prepared in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “Regulation (EU) 2016/679” or “GDPR”).

We understand that your personal data and the protection of the information you share with us is extremely important. That is why our Privacy Policy describes how we process your data and what measures we take to protect it.

This policy applies to you if you provide us with personal data by phone (by call or SMS), in an online registration form, by mail or by courier, through social networks, on a corporate or promotional website, through a mobile application or in any other way. Our privacy policy is an expression of our willingness to protect your personal information.

INFORMATION ABOUT THE PERSONAL DATA ADMINISTRATOR

Art.1. (1) "LITTLE FRIENDS" EOOD (the Company) is a personal data administrator, registered in the Commercial Register at the Registry Agency with UIC: 206174013, with registered office and management address: Sofia, Sofia region, Stolichna municipality, 53 Graf Ignatiev Str., entrance A, floor 1.

(2) This policy aims to clarify and present information and the conditions for exercising the rights of individuals in relation to the protection of their personal data processed by "LITTLE FRIENDS" EOOD in connection with the company's activities.

(3) The policy aims to inform you about the processing activities of your personal data, the purposes for which they are processed, the measures and guarantees for data protection, your rights and the way in which you can exercise them in accordance with the requirements of the GDPR and the relevant applicable legislation of the European Union and the Republic of Bulgaria.

(4) In implementation of the Personal Data Protection Policy in "LITTLE FRIENDS" EOOD and the purposes of the General Data Protection Regulation and the Personal Data Protection Act (PDPA), the Company processes your personal data in compliance with the following principles:

1. legality, good faith and transparency
2. goal limitation
3. data minimization
4. accuracy
5. storage limit
6. integrity and confidentiality

INFORMATION REGARDING THE COMPETENT SUPERVISORY AUTHORITY

Art.2. In the event of a violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission as follows:

Name: Personal Data Protection Commission

Headquarters and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

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

Phone: 02 915 3 518

Email: kzld@government.bg, kzld@cpdp.bg

Website: www.cpdp.bg

Art.3. For the purposes of this policy:

"Personal data" - is any information relating to the clients (natural persons and natural persons representing legal entities) of "LITTLE FRIENDS" EOOD, as well as that relating to its employees who are identified, or through which they can be identified directly or indirectly by means of an identification number or by one or more specific characteristics.

"Data Subject" - an individual who can be identified as a result of the processing of his or her personal data;

"Processing of personal data" - is any action or set of actions that "LITTLE FRIENDS" EOOD performs with respect to personal data by automatic or non-automatic means (collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, provision, updating or combination, blocking, erasure or destruction, etc.).

"Personal data processor" - is a natural or legal person, public authority, agency or other body that processes personal data on behalf of "LITTLE FRIENDS" EOOD;

"Recipient" - means a natural or legal person, public authority, agency or other body to which “LITTLE FRIENDS” EOOD discloses personal data, whether a third party or not. Public authorities that may receive personal data in the framework of a specific investigation in accordance with Union or Member State law are not considered “recipients”; the processing of such data by said public authorities complies with the applicable data protection rules in accordance with the purposes of the processing;

"Data subject consent" - is any freely given, specific and informed statement of will by which the natural person to whom the personal data relate unambiguously consents to their processing.

"Personal data breach" - means a breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

PERSONAL DATA

Art.4. In connection with our activities, "LITTLE FRIENDS" Ltd. processes personal data of the following categories of persons:

Service users.

Visitors to our website.

Recipients of advertising messages.

Art.5. In order to establish and exercise your rights, "LITTLE FRIENDS" EOOD processes the following personal data of you:

1. Data about your identity – your names;
2. Your personal contact details – telephone and electronic address (e-mail), permanent address and another address specified by you;
3. Other information: company, position, business sector, as well as any feedback you provide to us by mail, phone, email or through social media messages;
4. Information about the device or devices you are using or have used to access our site (e.g., your device make and model, operating system, browser, or IP address).
5. Details of emails and other electronic communications you receive from us, including whether those communications have been opened and whether you have clicked on any links in them. We want to make sure that our communications are useful and relevant to you, so if you do not open them or click on any links in them, we know that we need to improve the information we send you.
6. Information from other sources , such as our partners, specialized companies that provide information about their customers with their consent, in explicit or anonymized form (e.g. marketing or clinical research companies, financial institutions, social networks, etc.), including information about you that is publicly available.
7. "Cookies", as well as other tracking devices

So-called session (temporary) cookies are used to the extent necessary to ensure the secure and efficient functioning of our website and its use. The storage of session cookies on end devices or user application software intended for viewing information resources (Web browsers) is entirely under the control of the user. The information related to cookies is stored by the server after HTTP sessions in the service logs for no longer than the time necessary to complete the specific purpose being processed, or as required by law.

8. We use Google Analytics as a monitoring tool (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). Google Analytics uses cookies that allow us to track the number of visitors to the website, their source and to analyze how often and how the content of the website is used. You can install an opt-out tool that prevents such information from being collected from your visit ( https://tools.google.com/dlpage/gaoptout?hl=en )
9. Social media plugins (plug-ins)

We use social media to promote the company's activities. Each social media platform has its own privacy policy and processes your personal data.

10. Facebook

When you visit our website, Facebook (Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA) recognizes your profile and establishes a direct connection between your browser and your Facebook profile. In this way, the Facebook platform receives information about your IP address from your visit to our website. For more information, you can find Facebook's privacy policy here: https://www.facebook.com/policy.php . Other information that is processed by us and Facebook jointly is that provided to us in connection with our Facebook page. We have access to anonymous statistics about the activities that take place on our Facebook page, and we cannot categorically link or identify a specific profile through this data.

Art.6. (1) "LITTLE FRIENDS" EOOD does not collect or process personal data relating to the following:

1. reveal racial or ethnic origin
2. reveal political, religious or philosophical beliefs, or membership in trade unions
3. genetic and biometric data, data on health or data on sex life or sexual orientation.

(2) Personal data is collected by "LITTLE FRIENDS" EOOD by the persons to whom they apply.

(3) The company does not perform automated decision-making with data.

(4) The company does not process data about persons under 16 years of age, except with the express consent of their parents or representatives.

Art.7. Grounds for collecting, processing and storing your personal data

(1) “LITTLE FRIENDS” EOOD collects and processes your personal data based on the following:

You gave consent to the processing of your personal data for one or more specific purposes

Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract between us and you

The processing is necessary for compliance with a legal obligation that applies to us as a personal data controller

The processing is necessary to be Your vital interests are protected or to another individual

Processing is necessary for the performance of a task of public interest or in the exercise of official authority vested in us as a personal data controller;

The processing is necessary for the purposes of our legitimate/legal interest or that of a third party , except where such interests are overridden by your interests or fundamental rights and freedoms which require special protection of your personal data.

(2) “LITTLE FRIENDS” EOOD is a personal data controller in relation to your data as a user of our services. With respect to the personal data that you process using our services, "LITTLE FRIENDS" EOOD acts as a personal data processor.

Art.8. Purposes for which we use the personal data you provide to us:

1. To send you a response to an inquiry you have made about one of our products or services
2. To send you emails with news and offers from the company
3. To send you invitations to events we organize – independently or with our partners
4. For statistical purposes and analysis
5. To help us understand more about you as our customer, the products and/or services you use, the way you use them, and to provide you with better service from our employees;
6. To send you invitations to participate in surveys – online or in paper format.
7. To find ways to improve our products, services, applications or websites.
8. To create a profile on the site and ensure full functionality in providing our services
9. For individualization of a party to the contract
10. For accounting purposes
11. For statistical purposes
12. To protect information security
13. To ensure the implementation of the contract for the provision of the relevant service
14. To improve and personalize the service by offering you relevant promotional offers for products and services that may be of interest to you
15. To subscribe to our articles published on the blog of our website
16. For leaving comments on products and our articles published on our blog

 RIGHTS OF NATURAL PERSONS

Article 9. (1) As an individual whose data "LITTLE FRIENDS" EOOD processes, you have the following rights:

1. To receive information about your personal data being processed. You have the right to access your personal data that we process for the purposes set out above. If we process this data and we receive a request from you (or a third party authorised by you), we will provide this access free of charge. You also have the right to request a copy of your personal data that we process. Before providing access to your personal data or that of a person authorised by you, we may request proof of identity and details of your relationship with us or our partners so that we can find the data that concerns you.
2. To request a correction the data collected about you, if it is incorrect or has changed
3. Request deletion ("to be forgotten") of the personal data collected about you, except in cases where "LITTLE FRIENDS" EOOD processes your personal data in compliance with obligations arising from the law. You have the right to request that we erase your personal data without undue delay if:

- the personal data are no longer necessary for the purposes for which they were collected

- when you have withdrawn your consent

- when you have objected to the processing if it is unlawful

- when the personal data must be erased for compliance with a legal obligation under Union law or Member State law to which we are subject as a data controller

- when the personal data were collected in connection with the provision of information society services

- Under certain conditions, we may refuse to delete your personal data in cases provided for by law.

4. To request restriction of processing your personal data only for the purposes for which they were collected - in accordance with the requirements of the General Data Protection Regulation, the Personal Data Protection Act and the implementing acts (only in the cases provided for in the applicable legislation and to the extent that this does not contradict our regulatory obligations for processing your personal data);
5. Right to data portability Your personal data (only in the cases provided for in the applicable legislation, and to the extent that this does not conflict with our regulatory obligations to process your personal data);
6. To receive copies of documents with your personal data, after submitting a request on a form at an office of the Company
7. You can at any time to object to the processing of your personal data for the purposes of direct marketing carried out by "LITTLE FRIENDS" EOOD , by withdrawing your consent.

Article 10. (1) In case of violation of your rights under the General Data Protection Regulation, PDPA, you have the right at any time to file a complaint with the relevant supervisory authority, namely the Personal Data Protection Commission.

(2) You can appeal the actions and acts of "LITTLE FRIENDS" EOOD and the processors on behalf of the Company and by legal process before the relevant administrative court and before the Supreme Administrative Court.

Article 11. (1) You can exercise your rights under Art. 9 by filling out the form in writing. "Application for exercising rights in relation to the protection of personal data" (the Application) , which we will provide you upon request.

(2) The application You can send it personally or through your expressly authorized person with a notarized power of attorney on paper to any of our offices, as well as electronically, in accordance with the procedure of the ZEDEUU. When the application is drawn up as an electronic document, it should be signed with a qualified electronic signature.

(3) When submitting the application from an authorized person, you should also attach the relevant express power of attorney to it.

(4) In cases where, when exercising your rights under this chapter, there is a possibility that personal data will be disclosed to a third party, our relevant employee will provide you with access only to the part of them that applies to you.

Art.12. Within 30 (thirty) days from the receipt of your valid application for exercising rights in relation to the protection of personal data" "LITTLE FRIENDS" EOOD will provide you with written information regarding the actions taken by us, such as:

1. If you exercise your right to access personal data – will provide you with information about: the purposes for which the Company processes your personal data; the categories of personal data it processes; the recipients or categories of recipients to whom your personal data are or will be disclosed, in particular recipients in third countries or international recipient organizations to whom it provides them; where possible, the envisaged period for which your personal data will be stored, and if this is not possible, the criteria used to determine this period; the existence of the right to request from us the rectification or erasure of personal data or the restriction of the processing of personal data relating to you, or to object to such processing, your right to lodge a complaint with the competent supervisory authorities; where your personal data are not collected from you - any available information about their source, the existence of automated decision-making, including profiling, in accordance with the General Data Protection Regulation;
2. If you exercise your right to delete your personal data – will delete your personal data without undue delay, provided that the prerequisites for exercising this right of yours, provided for in the General Data Protection Regulation, the Personal Data Protection Act and its implementing acts, are met and to the extent that this does not conflict with our statutory obligations to process your personal data;
3. If you exercise your right to restrict the processing of your personal data – will restrict the processing of your personal data, in the cases provided for in the applicable legislation and to the extent that this does not conflict with our regulatory obligations to process your personal data, without deleting them, and we will inform you before the cancellation of the restriction of processing.
4. 4 . If you exercise your right to data portability – "LITTLE FRIENDS" EOOD will provide you with your personal data in a structured, commonly used and machine-readable format and will transfer your data to another controller, in the cases provided for in the applicable legislation, and to the extent that this does not conflict with our legal obligations to process your personal data.

(2) "LITTLE FRIENDS" EOOD will inform you in writing about any refusal of access, deletion, right to restriction of processing of your personal data or request to exercise the right to portability, as well as the reasons for the refusal within the period under paragraph 1.

(3) When your personal data is deleted or its processing is restricted, "LITTLE FRIENDS" EOOD will notify their recipients, who are responsible for their deletion or restriction, respectively.

(4) Our obligation to provide information under this article may be limited in whole or in part, taking into account your fundamental rights and legitimate interests and in the cases provided for by applicable laws.

(5) "LITTLE FRIENDS" EOOD has the right to extend the period under paragraph 1 up to 60 days, depending on the complexity and number of applications received in each individual case. The Company will notify you of any extension of the period, as well as the reasons for the extension of the period for our response within 30 days of receipt of your valid application. application for exercising rights in relation to the protection of personal data.

Article 13. (1) You can exercise the right to request correction of your personal data by filling out in writing application for correction of personal data (the application) , which we will provide you upon request.

(2) The application You can send it personally or through your expressly authorized person with a notarized power of attorney on paper to our office, as well as electronically, in accordance with the Electronic Document and Electronic Certification Services Act (EDCESA). When the application is drawn up as an electronic document, it should be signed with a qualified electronic signature.

(3) When submitting the application from an authorized person, you should also attach the relevant express power of attorney to it.

Article 14. (1) Within 30 (thirty) days from the receipt of your valid application for correction of personal data , "LITTLE FRIENDS" Ltd. will correct inaccurate personal data relating to you or complete incomplete personal data without undue delay.

(2) "LITTLE FRIENDS" EOOD will inform you in writing of any refusal to correct or supplement your personal data, as well as of the reasons for the refusal within the period under paragraph 1.

(3) When your personal data is corrected or supplemented, "LITTLE FRIENDS" EOOD will notify their recipients, who are responsible for their correction or addition, respectively.

(4) Our obligation to provide information under this article may be limited in whole or in part, taking into account your fundamental rights and legitimate interests and in the cases provided for by applicable laws.

Article 15. (1) You can exercise the right to object to the processing of your personal data for direct marketing purposes by filling out in writing Application for withdrawal of consent to the processing of personal data for direct marketing purposes (the Application) , which we will provide to you upon request.

(2) The application You can send it personally or through your expressly authorized person with a notarized power of attorney on paper in any of our offices, as well as electronically, in accordance with the Electronic Document and Electronic Certification Services Act (EDCESA). When the application is drawn up as an electronic document, it should be signed with a qualified electronic signature.

(3) When submitting the application from an authorized person, you should also attach the relevant express power of attorney to it.

Art.16. Within 30 (thirty) days from the receipt of your valid application for withdrawal of consent to the processing of personal data for direct marketing purposes "LITTLE FRIENDS" Ltd. will cease processing the personal data you have provided for direct marketing purposes and will provide you with written information regarding these actions.

(2) "LITTLE FRIENDS" EOOD will inform you in writing about any refusal to accept the application under paragraph 1, as well as about the reasons for the refusal within the period under paragraph 1.

(3) After "LITTLE FRIENDS" EOOD ceases the processing of the personal data provided by you, the Company will notify their recipients who are responsible for the cessation of their processing.

(4) Our obligation to provide information under this article may be limited in whole or in part, taking into account your fundamental rights and legitimate interests and in the cases provided for by applicable laws.

(5) "LITTLE FRIENDS" EOOD has the right to extend the period under paragraph 1 up to 60 days, depending on the complexity and number of applications received in each individual case. The Company will notify you of any extension of the period, as well as the reasons for the extension of the period for our response within 30 days of receipt of your valid application. application for withdrawal of consent to the processing of personal data for direct marketing purposes .

Period of storage of your personal data

Art.17. (1) “LITTLE FRIENDS” EOOD stores your personal data for a period no longer than the existence of your account on the website. After this period, "LITTLE FRIENDS" EOOD takes the necessary care to delete and destroy all your data without undue delay. In the general case, unless we have specified otherwise, your data is stored for a period of 2 (two) calendar years from the date of receipt.

(2) “LITTLE FRIENDS” EOOD Notifies you if the data storage period needs to be extended in order to fulfill the purposes, perform the contract, or in order to pursue legitimate interests. "LITTLE FRIENDS" EOOD or something else.

(3) “LITTLE FRIENDS” EOOD stores your data, provided on the basis of consent, until its explicit withdrawal, and this does not affect any publications and comments made in order to preserve the semantic integrity of the comments.

(4) “LITTLE FRIENDS” EOOD stores personal data that is required to be kept under applicable law for the relevant stipulated period, which may exceed the duration of your registration.

IN THE EVENT OF A Breach of the Security of Your Personal Data

Article 18. (1) If "LITTLE FRIENDS" EOOD establishes a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, we will notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.

(2) “LITTLE FRIENDS” Ltd. is not required to notify you if:

1. Has taken appropriate technical and organizational measures to protect the data affected by the security breach;
2. Has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;
3. Notification would require disproportionate effort.

THE PERSONS TO WHOM YOUR PERSONAL DATA IS PROVIDED

Article 19. In connection with the conclusion of contracts for the purchase and sale and delivery of the products offered by "LITTLE FRIENDS" EOOD services, "LITTLE FRIENDS" EOOD transmits the necessary information to:

- Courier or postal companies that need to deliver documentary or other shipments to you on our behalf

- Printers who need to prepare personalized materials for you

- Companies for sending mass emailing when you need to receive an email message from us.

Article 20. The administrator does not transfer your data to third countries.

DATA PROTECTION

Article 21 . "LITTLE FRIENDS" EOOD treats your personal data as strictly confidential. To protect it, a number of measures have been taken, including:

- We limit access to the premises in which we work to only those people who need to be there (for this purpose, we use access codes and cards, passwords, and other technologies related to restricting access to certain premises);

- We also implement access control to our information technology systems using firewalls, ID validation, logical segmentation and/or physical separation of our systems and information;

- We use methods such as encryption and pseudonymization of information;

- We never ask you to send us your password;

- We advise you to never enter an account number, password, or other sensitive information in an email to us.

ADDITIONAL PROVISIONS

• 1. This policy is approved by order of the representative "LITTLE FRIENDS" EOOD
• 2. For issues not covered by this Policy, the General Data Protection Regulation, the Personal Data Protection Act and other regulatory acts relevant to the activities of the Company shall apply. "LITTLE FRIENDS" Ltd.
• 3. Taking into account current trends, this privacy policy may be changed. The update date is indicated at the end of the document. All changes to this privacy policy will be applicable after their announcement in the future.