Data Controller

International Children’s Creativity Center (“ICCC”) is the data controller of your personal data that it receives in connection with:

  • The implementation of ICCC’s purposes for half- and full-day care services for children aged 2–6 years, and

  • The use of our website – https://iccf-bg.com/ (the “Site”).

Since we treat your personal data responsibly and in compliance with legal provisions, we inform you (“You”/“Your(s)”) about the purposes for which we use such data, how we process it, who has access, and more.


What Kind of Data We Collect, Why, and How Long We Store It

Admission Application

When you and your child(ren) wish to become part of the ICCC community, you complete an application form on our Site. We collect:

  • Parent and child(ren) names

  • Nationality

  • Date of birth

  • Phone numbers and email addresses

  • English-language proficiency in the family

Purpose:

  1. To keep in touch with you

  2. To determine the appropriate age group for your child(ren)

  3. To maintain our policy quota of foreign families

  4. To assess your child(ren)’s level of English

Retention:

  • If your child(ren) join our community, we process and store this data while you remain members, and for up to 5 years thereafter to protect our legal interests.

  • If we cannot offer membership or you withdraw during the application stage, we retain your data for up to 12 months and then delete it promptly.

Information about Parents and Children upon Entry

Upon acceptance into the ICCC community, we also collect:

  • Health data (e.g., allergies, chronic illnesses)

  • Immunization records and required tests

We may take photos of children for:

  • Annual directory

  • Daily teacher publications

  • School events and field trips

Retention:

  • Personal and health data: While part of our community, plus up to 5 years after departure.

  • Photographs: Until you withdraw consent, at which point we delete them promptly.

Site Browsing

Our Site is hosted by SuperHosting.BG OOD, acting as our data processor under contract. We collect server logs and technical data (IP address, URL requested, browser, device), which are stored anonymously so you cannot be personally identified.

Retention:

  • Site-browsing data is kept for 50 days and then automatically deleted.

Note: Our Site may link to third-party websites. We are not responsible for their data practices once you leave our Site.

Facebook and Instagram

We maintain pages on Facebook and Instagram but do not receive any personal data transmitted on those platforms. For details, consult Facebook’s and Instagram’s privacy policies.


Legal Grounds for Processing Your Personal Data

  • Legitimate interest in assessing and processing your application.

  • Contractual necessity for providing services, based on membership fees and signed agreements.

  • Legal obligation for collecting children’s health information under Bulgarian law.

  • Consent for processing and publishing photographs, valid until you withdraw it.

  • Legitimate interest in collecting anonymous browsing data to operate and improve our Site.


Third Parties Data Access – Receivers

We do not share your data with unrelated third parties. We may disclose data to:

  • Technical partners (e.g., SuperHosting.BG OOD, Google Analytics, Kinderpedia SRL) under contractual obligations

  • Legal, IT, or other consultants, but only when strictly necessary and for the duration of the consultation


Data Transfer

  • No transfers outside the EU/EEA. Our servers are located in Bulgaria.

  • Google Analytics may store anonymized data in third countries (e.g., the US); we rely on their privacy safeguards. See Google’s policy here.


Cookies; Collection and Processing of Communications and Usage Data

Site Cookies

We use cookies to enable Site functionality and improve our services.

  • Session cookies (deleted when you close your browser)

  • Persistent cookies (remain until you delete them, to recognize your browser on return)

You can manage cookies through your browser settings, but disabling them may limit Site functionality.

Third-Party Cookies

Our Site may include features from other websites that set their own cookies. To learn about those, consult the respective third-party cookie policies.

Information about Google Analytics

We use Google Analytics for anonymous usage statistics (visitor counts, search terms, pages visited, time spent). Cookies do not identify you personally. To opt out, visit Google’s opt-out page:
https://tools.google.com/dlpage/gaoptout?hl=en


Information Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access or disclosure.


Your Rights

Under the GDPR and applicable laws, you have the right to:

  • Request access to, correction, or deletion of your personal data

  • Restrict or object to processing

  • Obtain information about automated processing

To exercise these rights, email us at office@iccf-bg.com with details of your request. We may require proof of identity.

If you remain unsatisfied, you may lodge a complaint with the Bulgarian Personal Data Protection Commission:
https://www.cpdp.bg/


Amendments

This Policy was last updated in August 2024. Any changes will take effect upon publication on our Site.

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