Privacy Policy – OUR KiDS iMAGiNE™

PRIVACY POLICY

of SOLUTION FINDER Ltd.

LAST VERSION: October 25^TH, 2018

We, OUR KiDS iMAGiNE™, take seriously our responsibility to protect the personal data that you share with us. Personal data is any information related to you or to a person that you have legal rights to represent (eg. minors), which could identify you. Data that cannot be directly linked to you or to people you represent, is not considered personal data.

We do not collect sensitive data.

In view of Intellectual Property rights protection and financial fraud prevention we do collect personal data of kids provided to us by you as a holder of the parental responsibility in relation with your consent to our Website’s Terms & Conditions, which constitutes a contract between you and us. We do not make public any personal data of kids that may identify them. We do not provide services directly to children.

This Privacy Policy intends to clearly and in detail present to you:

What personal data we collect and process about you as a Registered User of our Website;
How we use that data;
In what way and how long we keep your personal data;
To whom we might disclose your personal data;
Your rights as a data subject and how you could exercise them.

We apply this Privacy Policy as a data controller with respect to your personal data submitted while you log into your Profile at www.ourkidsimagine.com or when you use our Online Store at www.ourkidsimagine.com/shop/ as a Registered User. It is not applicable to websites or services which we neither own, nor control. All terms used in this Privacy Policy shall have the meaning as per the Website Terms & Conditions.

I. Who we are

Data controller of your personal data is Solution Finder Ltd., legal entity registered in Bulgaria, UIC 204802195, address: 80, Alexander Malinov Blvd., Entr. 1, Atelie 14, Sofia 1799, Bulgaria, legal representative: Irina Simeonova.

Solution Finder collects and processes personal data in compliance with the personal data protection laws applicable in Bulgaria and the European Union.

Our website address is: https://www.ourkidsimagine.com

II. What personal data we collect and why we collect it

Personal data is any data which could be used to identify a natural person.

You are asked to provide us with personal data when you visit our Website and want to become a Registered User, or when you contact us through our online contact forms. We need to collect and process your personal data in order that you would be able to have access and use our services. Solution Finder is committed to limit the collection of personal data only to such data which is needed to provide you with the services in accordance with our Terms & Conditions, to ensure that its confidentiality is respected and to prevent unauthorized access to it. We collect personal data only through the User registration page, the Profile page, the checkout form of our Online Store and the contact forms on our Website. We do not share your personal data with any third party unless we are required by law.

We collect and process the following personal data in respect of your Profile as Registered User:

When making registration on our Website, as per your agreement with Solution Finder, you are required to provide the following data:
- First and last name
- Email address
- Country of residence

We collect this personal data upon your confirmation of acceptance of our Terms and Conditions, which starts a contractual relationship between you and Solution Finder, and we may contact you for administrative purposes only. We neither share this information with third parties, nor use it for marketing purposes.

Phone number is not a mandatory field for User registration, however we have given you the opportunity to provide it. Should you decide to do so, based on your explicit consent, we could only use it in one or more of the following cases: - your data protection; - verification of your identity for security and fraud prevention reasons; - to serve you better in respect of purchase of Products from us; - to coordinate with you any matter related to Intellectual Property rights, which you have granted to us by uploading drawings to www.ourkidsimagine.com.
We also ask you to share the reasons why you have chosen to use our Website. It is not a mandatory field, although it would help us better understand our customers and improve our offering.
Bank details – this personal data is required to facilitate royalty payments to you, as Representative or as Author, if aged 18 or over, when Art has been used for Commercial Realization. We would never ask you for your bank details outside of the form available on your User Profile page AND without sending you an official Art Commercial Realization Notification email prior to that. If you do not provide us with this type of data, we would not be able to transfer to you royalties associated with your Art copyright.

Our Website is not directed to individuals under 18. We do not knowingly collect personal data from anyone aged below 18. If you, as a parent, become aware that your kid has provided us with personal data without your consent, you should contact us at admin@ourkidsimagine.com.

We collect and process the following personal data in respect of the services we provide to you:

As our main activity is making publicly available kids’ Art, as well as developing products related to these, we do collect the following personal data about kids, when you, as Representative, decide to upload an image of their Art to www.ourkidsimagine.com:

First name and family name of the kid, who is the Art’s Author
Date of birth of the kid, the Art’s Author
Country of birth of the kid, the Art’s Author

Apart from first name and country, the rest of the kid’s personal data remains private and is available in your Profile only, access to which is granted to you and the Website administrator. We could use kid’s personal data only under the following two circumstances:

before we publish on our Website an image of kid’s Art, which you have uploaded as a Registered User, we may ask you to verify your relationship with the kid by showing us a document (a birth certificate). We need to ensure that you are the legitimate holder of parental responsibility for that kid and you may take decisions on her/his behalf;
if your kid’s Art is selected for Commercial Realization, we may ask you to verify your relationship with the kid by showing us a document (a birth certificate). We need to ensure that: a. you are the legitimate holder of parental responsibility for that kid; and b. the kid is still under your custody, i.e. if at that point your kid is no longer a minor, it is not you that would be entitled to receive the royalties related to the copyright, but your kid directly.

The kids’ personal data is collected based on the agreement between you and Solution Finder through your acceptance of our Terms and Conditions, as well as your Explicit Consent submitted to us when you decide to fill in your kid’s personal data under My Kids section of your private Profile on our Website. We do not share this information with any third party, and we do not take automated decisions based on that data.

We would not be able to protect kids’ rights, unless we collect their personal information. We are compliant with the General Data Protection Regulation of EU and we are committed to ensure confidentiality and personal data protection for any personal data that has been provided to us.

However, if you do not feel like sharing this type of data with us, please do not use our Website.

Please note that you are responsible for maintaining the confidentiality and security of your User Name and Password.

You can edit your personal data under your Profile / Edit section by selecting the respective personal data tab.

A complete list of the personal data you have provided to us is available under your Profile / View section.

You could check the visibility status of your personal data at any time under your Profile / Profile Visibility section.

We may also process personal data, provided by you as a User of our Website, for statistical or scientific purposes, i.e. in aggregate form, which wouldn’t allow your identification, as we are committed to protect the data and guarantee that it wouldn’t be processed for any other purpose.

We collect and process the following personal data with respect to your visit to our Online Store:

While you visit our Website, we will track:

Products you have viewed: we will use this, for example, to show you Products you have recently viewed
Location, IP address and browser type: we will use this for purposes like estimating taxes and shipping charges
Shipping address: we will ask you to enter this, so we can deliver your order

We will also use cookies to keep track of cart content while you are browsing our Website.

When you purchase from us, we will ask you to provide information including your name, billing address, shipping address, email, phone number, credit card/payment details and optional account information like Username and Password. We will use this information for purposes, such as to:

Send you information about your account and order
Respond to your requests, including refunds and complaints
Process payments and prevent fraud
Set up your account for our Online Store
Comply with any legal obligations we have, such as calculating taxes
Improve our Online Store offerings
Send you marketing messages, only if you choose to receive them

If you create an account, we will store your name, address, email and phone number, which will be used for your convenience through the checkout process of your future orders.

We generally store information about you for as long as we need to use it for the purposes it was originally collected and processed, as well as to the moment we are no longer legally required to keep it. For example, we will store fulfilled order information for 5 years for tax and accounting purposes. This includes your name, email, and billing and shipping addresses.

We would retain inactive accounts for 12 months, in case they have not been used for orders and we are not obliged therefore to keep them longer for tax and accounting reasons.

Data related to pending orders, i.e. those that have not been confirmed yet, will be kept for one day.

Data related to failed orders will be stored for one month in order to support the internal analysis of the reasons why the order failed.

Data related to cancelled orders will be stored for one month in order to support the internal analysis of the reasons why the order was cancelled.

We will also store comments or reviews, if you choose to leave any.

We also collect, through our suppliers, and may process the following data:

When selecting third party service providers, we take the time to investigate and analyze their personal data protection practices and policy, as well as the data management settings available to us. Some of them are processors of data in view of our agreements with them and the services we use, provided that this data is not always personal data. Below you could find the type of data they collect and/or process on our behalf:

log files – those are not personal data
data related to transaction fulfillment when you place an order with our Online Store
We have built our Website on WordPress. By default, WordPress does not collect any personal data about you as a Visitor of our Website. However, some plugins that run on WordPress and we have them active on our Website, may collect personal data.

Comments

When Visitors leave comments on the Website, we collect the data shown in the comments form, as well as the Visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service in order to see if you are using it. The Gravatar service privacy policy is available here. After approval of your comment, your Profile picture is visible to the public in the context of your comment.

Media

If you upload images to the Website, you should avoid uploading image files with embedded location data (EXIF GPS). Visitors to the Website can download and extract any location data from images on the Website.

Contact forms

Personal data is captured when someone submits a contact form. The personal data provided by you in this way is stored in our database on the server hosting our Website. We keep the data you have submitted for one year for customer service purposes. We do not use the information for marketing purposes and we do not share it with third parties unless required by law.

Cookies

If you leave a comment on our Website, you may opt-in to saving your name, email address and Website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have a Registered User account and you log in to this Website, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

Embedded content from other websites

Articles on our Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the Visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content, if you have an account and are logged in to that website. As those are third-party websites, kindly be advised to read the Privacy Policy applicable by any of those providers in case you decide to use their services.

Analytics

We have enabled through third party plugin events tracking on our Website, which means that we are tracking the clicks you make while browsing our content. We use this information for Website optimization. We keep this data for 14 months. Collection of this type of data does not allow personal identification and is not therefore regarded as personal data.

III. Who we share your data with

If you choose to pay via your PayPal account, then based on our payment processing agreement with PayPal, you are redirected to a PayPal server, through secure connection, and we share with them information you have provided to us only in view of transaction fulfillment. In addition, transaction and experience information is collected by PayPal, as a data collector through your profile with them. We do not have access to such data. You could check PayPal Privacy Policy here.

IV. How long we retain your data

If you leave a comment, the comment itself and its metadata are retained indefinitely. This is done so that we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

We also store personal data provided by Users in their User Profile. All Users can see, edit, or delete their personal data at any time (but they cannot change their Username) unless we are legally required to keep the data longer, for tax purposes it will be a 5-year period. The Website administrator, too, can see and edit that information.

V. What rights you have over your data as a data subject

If you have a Registered User account on our Website, or if you have left any comments, you can request to receive an exported file of your personal data we hold at the time of your request, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not apply to data we are obliged to keep for administrative, legal, or security purposes.

You CANNOT delete your own account by yourself for several regulatory reasons. In case you would like to do so, please send your request along with your name, phone number and email address to admin@ourkidsimagine.com, so that we could verify your identity, the status of your past and current orders, and be able on this basis to ensure that the data storage would not be required for tax or other legal purposes. We will respond to your request within 30 days of its receipt with indication of whether we have deleted your account and any personal data associated with it, or in case we have not done so, the specific reason behind.

In addition to the above, as a data subject your rights as per the EU General Data Protection Regulation, are as follows:

Right to information, access, rectification and erasure – You have the right to ask us about what personal data we have collected about you and how it has been processed, whether it has been stored with us and for how long it will be retained, why and who has access to it. You can ask us to let you see or to provide you with a copy of all personal data that we have about you. You can also ask us to correct that personal data, if an update is required or if you believe the data is not accurate. Moreover, you can request at any time the personal data we keep about you to be deleted. However, please note that we can proceed with deletion of your personal data only if there is no statutory obligation or prevailing right of Solution Finder to retain such personal data. In the event that you request deletion of your personal data, please kindly note that you would not be able to use any service provided by Solution Finder, which requires Solution Finder to process your personal data.
Right to withdraw a consent – If your personal data has been processed based on your explicit consent, you have the right to withdraw that consent at any time. This means that from the date of your consent’s withdrawal Solution Finder shall not use your personal data for the purpose of the consent you have earlier provided to us. However, your consent’s withdrawal does not affect the lawfulness of your personal data processing done that far based on the consent you had provided to us prior to its withdrawal.
Right to object – You can object the processing of your personal data by Solution Finder in case you believe that Solution Finder has processed your personal data with a purpose other than those you have agreed to through our Terms & Conditions or through the explicit consent you have provided to us.
Rights in relation to Automated individual decision-making – you have the right to oppose against being subjected to decisions based solely on automated processing affecting you significantly. It should be noted though that Solution Finder is not applying automated individual decision-making in any of its activities.
Right to data portability – you can request that your personal data we have collected be transferred back to you or to another data controller. If you would like to exercise this right, please send us your request through our Contact Form. We will carefully consider your request and discuss with you how we can best fulfill it.

When you wish to exercise any of your rights as a data subject or as a Representative of a data subject you must express your request in writing. In order to verify your identity and to be able to respond to you, we may ask you for your personal data.

Hereby, we have tried to provide you with as much comprehensive information as possible on why we need your personal data and how we will handle it. In case you have any questions on this matter, please contact us through our Contact Form.

VI. Supervisory Body

If you think that your rights in respect of personal data protection have been violated, you may contact the Commission for Personal Data Protection at https://www.cpdp.bg/en/. You may also submit your complaint in your country of residence, your country of work, or the country where you believe your rights have been violated.

VII. Where we send your data

Visitor comments may be checked through an automated spam detection service.

When you place an order to our Online Store, your data is sent through secure connection to the servers of our partners servicing payment processing and order delivery.

VIII. Our contact information

In respect of this Privacy Policy you can contact us at: admin@ourkidsimagine.com

IX. Additional information

a. How we protect your data

We have implemented SSL (Secure Sockets Layer) for the entire website and we encrypt data flow between the user browser and our web server.

No personal data is sent by email for any reason whatsoever.

b. What third parties we receive data from

We do not receive any personal data about you from third parties.

c. What automated decision making and/or profiling we do with user data

We do not take automated decisions based on the personal data you have shared with us, including profiling of users.

X. Who on our team have access

Employees of Solution Finder have access, on as needed basis, to the information you provide. For example, they can access order information like what you have purchased, when you purchased it and where it should be sent, in order to help fulfill orders, process refunds and support you. They are bound by confidentiality agreements, including commitment to strictly follow personal data protection procedures and to comply with the present Privacy Policy.

XI. What we share with others

We share information with third parties who help us provide our services to you, as presented below:

BuddyPress

Any BuddyPress component that might track your activity within the site or on other sites as a Registered User of our Website has been disabled. Therefore, we do not store any kind of personal data related to your activity on Internet. We have enabled only those components of BuddyPress that would improve significantly your User experience within our Website without breaching your individual rights.

Payments

We accept payments through PayPal. When processing payments, some of your data will be passed to PayPal, including information required to process or to support the payment, such as the purchase total and billing information. Please see the PayPal Privacy Policy for more details.

Delivery

We collaborate with the following delivery partners with whom we share your name, your phone number and your shipping address, so that they could fulfil the delivery to you once you have placed an order on our Online Store:

DHL – you could read more about their Privacy Policy here.
Speedy – their Privacy Policy is available here.
Bulgarian Posts – check for their Privacy Policy here.

Privacy Policy changes

We reserve the right to amend our Privacy Policy at any time, provided that you are notified about any such change through a notice on our Website.

LAST VERSION: October 25TH, 2018