Privacy Policy | Connective Minds

PERSONAL DATA PROTECTION POLICY (PRIVACY POLICY)

PREAMBLE

This website (www.cominds.education), hereinafter referred to as the “Website,” is operated by CONNECTIVE MINDS LEARNING Ltd., registered in the Bulgarian Commercial Register with UIC 208308710, with registered office and address of management at 99 Tsarigradsko Shose Blvd., Sofia 1113, Slatina District, Bulgaria, represented jointly and severally by Antonina Nikolova Kardasheva and Petar Ognianov Mitev, hereinafter referred to as the “Administrator” and/or the “Company”.

In this Personal Data Protection Policy and throughout the Website, the terms “we,” “us,” and “our” refer to CONNECTIVE MINDS LEARNING Ltd. The Company operates and maintains the Website (also referred to as the “website” or “site”), including all information, tools, and services available to you as a user, provided that you accept all stated terms of use, policies, rules, and notices. By visiting our Website, you engage with our “service” and agree to comply with the following terms and conditions (the “Policy,” “Rules”), including any additional terms and conditions referenced herein and/or available via hyperlink.

The Administrator is committed to protecting your personal data. This Policy sets out how we use and safeguard any information you provide when using our Website. If you have any questions or comments regarding this Privacy Policy, please contact us at: info@cominds.education.
We will not sell, provide, trade, or disclose your email addresses and personal data to anyone for any reason, in compliance with the Bulgarian Personal Data Protection Act and the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679.
The person responsible for personal data protection is the Company’s managing director(s).
The Administrator takes care to maintain the security of your personal information. We have implemented appropriate electronic and managerial procedures to prevent unauthorized access, alteration, disclosure, or loss of your personal information. We are not responsible for security breaches or actions taken by third parties that may obtain the information. We undertake to inform you promptly if such malicious actions occur.
Your personal data are stored for as long as you have consented to receive our newsletter, and until you receive a written response from us if you have provided personal data via the contact form in the “Contacts” section for the purpose of written communication.

This Privacy Policy explains how the Company uses the personal data we collect from you when you use our Website.

Contents

Section I: On what legal basis do we collect your personal data?
Section II: For what purpose do we collect your personal data?
Section III: What data do we collect?
Section IV: How do we collect your data?
Section V: How will we use your data?
Section VI: How do we store your data?
Section VII: Marketing and advertising
Section VIII: What are your data protection rights?
Section IX: What are cookies?
Section X: How do we use cookies?
Section XI: What types of cookies do we use?
Section XII: How can you manage cookies?
Section XIII: Privacy policies of other websites
Section XIV: Changes to our privacy policy
Section XV: How to contact us
Section XVI: Responsibilities of the Administrator and the User in personal data processing
Section XVII: How to contact the competent supervisory authority

Legal basis for collecting, processing, and storing your personal data

Art. 1. (1) The Administrator collects and processes the personal data of the User in connection with the use of the website www.connectiveminds.com and the conclusion of contracts with the Company on the grounds of Art. 6(1) of Regulation (EU) 2016/679 (GDPR), and in particular on the following bases:

your explicit consent as a User;
performance of the Administrator’s obligations under a contract with you;
compliance with a legal obligation applicable to the Administrator;
the legitimate interests of the Administrator or a third party.

(2) By accepting these rules and this Privacy Policy, you guarantee that the personal data you provide are true and accurate and undertake to notify us of any changes. Any loss or damage caused to the Website, the responsible person, or any third party due to false, inaccurate, or incomplete information provided in a registration form shall be the sole responsibility of the User.

Art. 2. In order for the User to use certain pages and functions of the Website or to subscribe to a service offered via the Website, the Administrator requires the provision of personal identification information: first and last name, email address, phone number, workplace data, field of activity, and IP address.

Purposes and principles of collecting, processing, and storing personal data

Art. 3. (1) We collect and process personal data you provide in connection with the use of the Website, including for the following purposes:

accounting purposes;
statistical purposes;
information security;
ensuring the provision of information related to the Website’s activity and the Administrator;
sending a newsletter upon your request.

(2) We adhere to the following principles when processing your personal data:

lawfulness, fairness, and transparency;
purpose limitation;
data minimization and relevance to processing purposes;
accuracy and keeping data up to date;
storage limitation;
integrity, confidentiality, and ensuring an appropriate level of security.

(3) In processing and storing personal data, the Administrator may process and store personal data to protect its legitimate interests, including:

compliance with obligations toward the Bulgarian National Revenue Agency, the Ministry of Interior of the Republic of Bulgaria, and other state and municipal authorities.

III. What types of personal data our Company collects, processes, and stores

Art. 4. (1) The Company carries out the following operations with the personal data you provide for the following purposes:

Registration in the contact form – the purpose is to enable written communication with the organization managing the Website.
Impact assessment conclusion: Based on the conducted impact assessment, the “Contact form registration” operation is permissible and provides sufficient safeguards for the rights and legitimate interests of data subjects under the GDPR.
Newsletter distribution – the purpose is to administer the process of sending newsletters to users who have requested them. Given the limited scope of personal data collected, a data protection impact assessment is not required.

(2) The Administrator processes the following categories of personal data and information for the following purposes and legal bases:
Your identifying data (email, first and last name, phone number, workplace, field of activity, etc.)

Purpose: (1) contacting the user and sending information, (2) user registration on the Website, and (3) sending a newsletter.
Legal basis: newsletter data are processed based on your explicit consent – Art. 6(1)(a) GDPR.

(3) The Administrator does not collect or process special categories of personal data, including data that reveal:

racial or ethnic origin;
political opinions, religious or philosophical beliefs, or trade union membership;
genetic or biometric data, health data, or data concerning a person’s sex life or sexual orientation.

(4) Personal data are collected by the Administrator directly from the data subjects.
(5) The Company does not carry out automated decision-making.

Art. 5. (1) With regard to personal data provided by you as legal representatives or authorized persons of corporate commercial partners, the Company performs the following operations for the following purposes:

Conclusion and performance of a commercial transaction: we process only the full names of the legal representative or an authorized person.
Impact assessment conclusion: Given the limited number of individuals and the limited scope of collected data, a data protection impact assessment is not required.

(2) The personal data are collected by the Administrator from the data subjects and from the Commercial Register at the Registry Agency.
(3) The Company does not carry out automated decision-making.

Art. 6. The Administrator may use “cookies” to ensure full website functionality, improve user experience, for statistical purposes, easier access, etc., which you agree to by using the Website. You can control and/or delete cookies at any time via your browser settings. Cookies do not constitute personal data and are not used to identify website visitors or users.

How do we collect your data?

Art. 7. You directly provide the Company with most of the data we collect. We collect and process data when you:

register via the contact form in the “Contacts” section, which constitutes your consent to provide personal data. We use this information to administer your written inquiry and to provide information about our activities.
voluntarily provide feedback via email.
use or browse our Website via your browser’s cookies.
The Company may also receive your data indirectly from sources such as Google, Facebook, Instagram, YouTube, etc.
subscribe to our marketing email newsletter by providing only your email address. Newsletter subscription is voluntary and you may unsubscribe at any time via the unsubscribe link or by notifying us via email or phone. We do not share our list of registered users with other persons or organizations.

How will we use your data?

Art. 8. The Administrator collects your data in order to send you information about its activities.

Art. 9. The Administrator does not transfer, sell, or exchange your data for marketing purposes to third parties outside the Company. Data provided to third parties are used only to deliver our services, e.g., to media agencies and technical providers for marketing materials in physical or digital format.

Art. 10. (1) At its discretion, the Administrator may transfer some or all of your personal data to processors for the purposes you have agreed to, in compliance with GDPR requirements.

(2) The Administrator will notify you if it intends to transfer personal data to third countries or international organizations.

How do we store your data?

Art. 11. The Company securely stores your data in digital form in a secure environment and uses SSL (Secure Socket Layer) for data transfer.

Art. 12. (1) The Administrator stores your personal data no longer than the time required to provide a written response to an inquiry submitted via the contact form, and until you withdraw your consent to receive the newsletter, but not longer than necessary under GDPR. After the expiry of this period, the Administrator will take the necessary steps to delete and destroy your data without undue delay or to anonymize them.

(2) The Administrator will inform you if the retention period needs to be extended due to a legal obligation or legitimate interests of the Administrator.

Art. 13. The Administrator stores the personal data of legal representatives of commercial partners for the duration of contract performance and for compliance with legitimate interests and legal obligations, which may exceed the contract term.

VII. Marketing and advertising

Art. 14. (1) The Company may send you information about products and services we believe may be of interest to you.

(2) If you have agreed to receive marketing emails, you can opt out at any time using the unsubscribe option in the email.

VIII. What are your data protection rights?

Withdrawal of consent

Art. 15. You may withdraw consent at any time by submitting the relevant form (Appendix No. 1) or a free-text request via email. We will send verification instructions. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Right of access

Art. 16. You may request confirmation whether we process your data and obtain access and a copy of the processed personal data. Access is free of charge, but an administrative fee may apply in case of repetitive or excessive requests.

Right to rectification

Art. 17. You may request correction or completion of inaccurate or incomplete data via email (Appendix No. 4 or free-text request).

Right to erasure (“right to be forgotten”)

Art. 18. You may request deletion under the GDPR grounds listed, subject to exceptions (freedom of expression, legal obligations, public interest, legal claims, etc.). Verification is required.

Right to restriction

Art. 19. You may request restriction of processing in the stated cases; verification is required.

Right to data portability

Art. 20. Where applicable, you may request your data in a readable format and/or direct transfer to another controller where technically feasible. Data will be provided in XML after verification.

Right to be informed

Art. 21. You may request information about recipients to whom data were disclosed. The Administrator may refuse if impossible or requiring disproportionate effort.

Right to object

Art. 22. You may object at any time to processing, including profiling or direct marketing.

Rights in case of a personal data breach

Art. 23. Where a breach poses a high risk, the Administrator will notify you without undue delay, unless GDPR exceptions apply.

What are cookies?

Art. 24. Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information automatically through cookies or similar technology. Cookies are also used to personalize content you see. For more information, visit allaboutcookies.org.

How do we use cookies?

Art. 25. The Company uses cookies to improve your experience, including:

selecting the appropriate website language;
understanding how you use our Website.

What types of cookies do we use?

Art. 26. Our Website uses the following cookies:

Functionality – to recognize you and remember preferences (e.g., language). This may include a mix of first-party and third-party cookies.
Advertising – to collect information about your visit, viewed content, followed links, browser/device information, and IP address. The Company may share limited aspects of such data with third parties for advertising purposes, including advertising partners, which may result in ads on other websites based on your browsing patterns on our Website.

XII. How to manage cookies

Art. 27. You can choose whether to accept cookies. Most browsers automatically accept cookies, but you can change settings to refuse them. This may prevent you from fully benefiting from the Website.

XIII. Privacy policies of other websites

Art. 28. The Website may contain links to other websites. This Privacy Policy applies only to our Website. If you click on another website’s link, you should read their privacy policy. The Company is not responsible for the processing of your personal data by other websites accessed through hyperlinks published on our Website.

XIV. Changes to our privacy policy

Art. 29. The Company keeps its privacy policy under regular review and posts any updates on this page. This Privacy Policy was last updated on 18.12.2025.

Art. 30. Each time you use this Website, you will be bound by this Policy and should review it to ensure you agree with its terms.

How to contact us

Art. 31. If you have questions about this Policy, the data we hold about you, or if you wish to exercise your rights, please contact us:
Email: info@connectiveminds.com

XVI. Responsibility of the Administrator and the User in personal data processing

Art. 32. The Administrator and the person responsible for processing personal data are responsible for ensuring appropriate procedures and policies to maintain accuracy and currency of personal data, taking into account the volume of collected data, how quickly it may change, and other relevant factors.

Art. 33. The User is responsible for providing false personal data, as well as third-party data used without that third party’s knowledge and consent.

Art. 34. The Administrator is not liable for damages caused by false or incomplete data provided by users.

Art. 35. The Company is not liable for damages suffered by users as a result of phishing attacks and other unlawful actions by third parties against users.

XVII. How to contact the competent supervisory authority

Art. 36. If you wish to submit a complaint or believe the Company has not addressed your concern satisfactorily, you may contact the Commission for Personal Data Protection (CPDP), Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., Information and Contact Center – Tel. +359 2 91 53 518, Email: kzld@cpdp.bg, website: www.cpdp.bg.

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Appendix No. 1

Form for Withdrawal of Consent for Processing Purposes

Your name*: .........................
Your email address used on the website*: .........................
Contact details (e-mail)*: .........................

To:
CONNECTIVE MINDS LEARNING Ltd., registered in the Bulgarian Commercial Register with UIC 208308710, with registered office and address of management at 99 Tsarigradsko Shose Blvd., Sofia 1113, Slatina District, Bulgaria, represented jointly and severally by Antonina Nikolova Kardasheva and Petar Ognianov Mitev

By this document, I hereby withdraw my consent for the processing of my personal data provided by me for the purposes of receiving a newsletter, advertising messages, or other marketing materials, having been informed of the conditions for withdrawing consent in accordance with the mandatory information on data protection rights published on the website.

In case your rights under the above or applicable personal data protection legislation are violated, you have the right to file a complaint with the Commission for Personal Data Protection, as follows:

Name: Commission for Personal Data Protection (CPDP)
Registered office and address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Correspondence address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Telephone: +359 2 915 3 518
Website: www.cpdp.bg

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Appendix No. 2

“Right to be Forgotten” Request – Erasure of Personal Data Related to Me

Your name*: .........................
Your email address used to register or used on the website*: .........................
Contact details (e-mail)*: .........................

Please delete from your databases all personal data that you collect, process, and store, provided by me or by third parties related to me, as identified above.

I declare that I am aware that some or all of my personal data may continue to be processed and stored by the controller for the purposes of complying with its legal obligations.

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Appendix No. 3

Request for Data Portability

Your name*: .........................
Your email address used to register or used on the website*: .........................
Contact details (e-mail)*: .........................

Please send all personal data related to me that are collected, processed, and stored in your databases in XML format to:

E-mail: .........................

Controller receiving the data: .........................
Name: .........................
Identification number (UIC/BULSTAT/CPDP registration number): .........................
E-mail: .........................

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Appendix No. 4

Request for Data Rectification

Your name*: .........................
Your email address used to register or used on the website*: .........................
Contact details (e-mail)*: .........................

Please rectify the following personal data that you collect, process, and store, provided by me or by third parties related to me, as follows:

Data to be rectified:
..................................................

Please rectify in the following manner:
..................................................