PRIVACY POLICY OF www.kinderkraft.bg

Information about the company that processes your personal data:

Name: Newviva Ltd.

Company ID (EIK): 204417228

Registered office: Prof. Aleksandar Tanev St., bl. 460A, entr. 2, Mladost district, Sofia, Bulgaria

Correspondence address: 16 Aleksandar Malinov Blvd., Sofia

Telephone: +359 887 132 548

Email: office@newviva.bg

Information about the competent supervisory authority for data protection:

Name: Commission for Personal Data Protection

Registered office and correspondence address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria

Telephone: +359 2 915 3 518

Website: www.cpdp.bg

NEWVIVA LTD. (HEREINAFTER "THE COMPANY" OR "THE CONTROLLER") CARRIES OUT ITS ACTIVITIES IN ACCORDANCE WITH 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.

This information aims to inform you about all aspects of the processing of your personal data by the Company and the rights you have in relation to this processing.

LEGAL BASIS FOR COLLECTING, PROCESSING AND STORING YOUR PERSONAL DATA:

The Company collects, stores and processes your personal data in order to provide a service and in connection with the use of the online shop www.kinderkraft.bg, on the basis of Art. 6(1) of Regulation (EU) 2016/679, and more specifically on the basis of:

Art. 6. (1) Customer data is collected on the basis of:

1) a contract;

2) the customer's explicit consent;

3) the legitimate interests of the Company; or

4) the legal obligations of the Company.

Customer data is collected when a customer places an order in our online shop and/or registers a user account after expressly accepting the Terms and Conditions, which contain the mandatory information on data protection rights. The data processed by the Controller is:

• Customer's name
• Delivery address
• Current telephone number
• Bank account details (where the customer wants to return a purchased product and receive a refund)
• User data related to the use of our website
• Data from your ID card and any other information related to a job application (if you apply for a job with us)

We may provide our customers' data to third parties (for example couriers or an accountant) only to fulfil a legal obligation or to protect the legitimate interests of the Controller.

As a customer, you must expressly consent to your data being processed for marketing purposes, including newsletters and advertising messages. Without your consent, your data is not used for these purposes.

Personal data of the Company's partners

Art. 3. (1) The Company collects, stores and processes personal data of its partners who are natural persons and of the legal representatives or proxies of its partners who are legal entities, for the performance of a contract. (2) Partner data is collected when a contract is concluded with the Company or when such a contract is being prepared. (3) Data of the legal representatives of partners that are legal entities is collected from them, as well as from the Commercial Register at the Registry Agency or the relevant public register. (4) Partner data may be provided to data processors only for the purposes of performing the contract, and to third parties only to fulfil a legal obligation or to protect the legitimate interests of the Company.

At NEWVIVA Ltd. we follow these principles when processing your personal data:

• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimisation and relevance to the purposes of processing
• Accuracy and up-to-date data
• Storage limitation in line with the purposes
• Integrity and confidentiality, with an appropriate level of security of personal data

What types of personal data does NEWVIVA Ltd. (the Controller) collect, process and store?

(1) The Company carries out the following operations with personal data for the following purposes:

• Registration of a user in the online shop www.kinderkraft.bg and performance of a contract for the sale of products, services, etc. – to create an account linked to the online shop, through which products offered by the Company are purchased, delivered and, if necessary, returned or cancelled. The account is also used for a loyalty bonus system.
• Conclusion and performance of a commercial transaction with a customer or partner – to conclude and perform a contract and administer it.
• Sending information messages – to administer messages to customers about improvements or changes to the services, the shipping and delivery of purchased products, and the history of orders, in accordance with the service contract.
• Sending a newsletter – to administer the sending of newsletters to customers who have requested them.

(2) The Controller processes the following categories of personal data for the following purposes and on the following grounds:

• Data: your identifying data (first and last name, email, telephone).
• Purpose: 1) user registration; 2) contacting the user and sending information, including – if requested – newsletters and advertising messages; 3) delivery of orders placed through our online shop www.kinderkraft.bg.
• Legal basis: by accepting the Terms and Conditions, registering on the website and purchasing, a contractual relationship is created between NEWVIVA Ltd. and you, on the basis of which we process your personal data – Art. 6(1)(b) GDPR.
• Delivery and/or return of purchased products.
• Other data processed by the Company: when you visit our website or your account, the Controller collects the IP address used.
• Purpose: improving the security of the service and localising the interface, statistical and marketing research.
• Legal basis: processing is necessary for the performance of a contract to which the data subject is a party – Art. 6(1)(b) GDPR. Before an account is created, the IP address is collected on the basis of the legitimate interests of the Controller – Art. 6(1)(f) GDPR.
• Data for issuing an invoice to an individual: if you want an invoice as an individual, you must provide your personal identification number (EGN).
• Purpose: issuing an invoice for payments under a concluded contract.
• Legal basis: by accepting the Terms and Conditions and registering on the website, or by concluding a written contract, a contractual relationship is created between NEWVIVA Ltd. and you – Art. 6(1)(b) GDPR.

(3) We do not collect or process sensitive personal data that:

• reveals racial or ethnic origin;
• reveals political, religious or philosophical beliefs, or trade union membership;
• concerns genetic or biometric data, health, sex life or sexual orientation.

(4) Personal data is collected by the Company from the persons to whom it relates. (5) The Company does not carry out automated decision-making.

How long we keep your personal data:

Art. 4 (1) The Company keeps your personal data for no longer than your account exists on the website. After that, the Controller takes the necessary care to delete and destroy all your data without undue delay.

(2) The Company will inform you if the storage period needs to be extended to fulfil the purposes, perform the contract, for the legitimate interests of the Company, for accounting purposes or otherwise. The Company keeps personal data that it is required to keep under applicable law for the period prescribed, which may exceed the existence of your registration.

Transfer of your personal data for processing

Art. 5. (1) The Company may, at its discretion, transfer some or all of your personal data to data processors to fulfil the purposes of processing, in compliance with Regulation (EU) 2016/679.

(2) The Company will inform you if it intends to transfer some or all of your personal data to third countries or international organisations.

Your rights

Under data protection law, you have the right to:

• withdraw your consent to the processing of your personal data;
• access information on whether and for what your personal data is used;
• rectification or completion of your data;
• erasure ("right to be forgotten");
• restriction of processing and data portability;
• object to direct marketing;
• be informed to whom your personal data has been disclosed.

Right to object to the use of your personal data

If you wish to exercise any of the above rights, please contact us at office@newviva.bg.

Cookies

Cookies are small text files that a website stores in your browser. On www.kinderkraft.bg we use two types of cookies:

• Necessary – they make the site work: the cart, logging in, checkout and remembering your cookie choice. They do not require consent and cannot be switched off.
• Statistics and advertising – Google Analytics (Google Ireland Ltd.) and Meta Pixel (Meta Platforms Ireland Ltd.). We use them only if you click "Accept" in the cookie banner. If you click "Decline", these cookies are not stored.

Videos on product pages are loaded from YouTube (youtube-nocookie.com) only when you click the play button.

How to change your choice: at any time via the "Cookie settings" link at the bottom of the site. You can also delete cookies in your browser settings. Withdrawing consent does not affect the lawfulness of processing before the withdrawal.

This is a translation for your convenience. In case of any discrepancy, the Bulgarian version prevails.