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Privacy policy and GDPR

 Information about the Data Controller:

**Working Mama Ltd.** is a company registered in the Commercial Register of the Registry Agency with UIC 207605420, with headquarters and registered address at: Sofia 1680, Krasno Selo district, "Rodopski Izvor" Street No. 38, Apt. 31.

Working Mama Ltd. operates through the website "www.workingmama.coach" and all its subpages, hereinafter referred to as "the Site".

 

Contact Information:

Email Address: office@workingmama.coach

 

What are Personal Data?

Personal data is any information or set of information that identifies you or could be used to identify you (along with other information you provide in the contact form).

The processing of personal data includes collection, storage, transfer, correction, updating, deletion, destruction, and all other actions performed with your personal data.

In the following paragraphs, you will find detailed information regarding the processing of your personal data based on the legal grounds on which we process them.

 

Grounds and Purposes for Using Your Personal Data

1. For the purpose of concluding contracts and providing services through the Platforms, we process your personal data, which you provide by filling out order forms for our product, sending inquiries, and messages through the Platforms, as well as when you make subsequent contact with us in the course of reviewing your inquiries and messages. The data you provide is used to provide you with information and send notifications about everything related to the services you use with us.

  Data we process on this basis:
   - Information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:
     - Personal contact data: names, email, phone number;
     - Information about the inquiry made to us;
     - Correspondence related to overall service: email, letters, information about your requests for troubleshooting, complaints, feedback we receive from you;
     - Created unique user number;
     - Information from your actions on the site.

   **When do we delete data collected on this basis:**
   - We delete data collected on this basis 2 years after the termination of the contractual relationship, regardless of whether due to the expiration of the contract term, termination, or other grounds.

2. Direct Marketing – if you have provided consent to receive marketing messages, we will collect and process your personal data for the purpose of sending offers for products/services you are interested in. In this regard, we may send you commercial messages through the following electronic communication channels (email, SMS, etc.) containing general and thematic information; information about products complementing the services used, and other business communications.

   Data we process on this basis:
   - On this basis, we process only the data for which you have given us your explicit consent. Specific data is determined on a case-by-case basis. Usually, this data includes an email address and name.

 

Providing data to third parties:
   - On this basis, we may provide your data to marketing agencies, Facebook, Google, or other similar entities.

 

When do we delete data collected on this basis?:
   - Data collected on this basis is deleted upon request from you or 12 months after their initial collection.

 

Withdrawal of consent:
   - Provided consents can be withdrawn at any time by sending an email to us at the indicated contact email addresses. Withdrawal of consent does not affect the performance of contractual obligations. If you withdraw your consent to process personal data for one or all of the ways described above, we will not use your personal data and information for the specified purposes. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

3. Legitimate Interest – processing your data is necessary to comply with our obligations under current legislation. There may be cases where we use or transmit information to protect our rights and business. These may include:
   - Measures to protect the Platforms and their users against cyber-attacks;
   - Measures to prevent and detect fraud attempts, including transmitting information to competent public authorities;
   - Measures for managing various other risks;
   - Legal provisions;
   - Contractual interest – we process your data for the purpose of providing services under concluded contracts on the Platforms.

 

Your consent – we rely on your consent to send you commercial messages, as well as to inform and include you in our projects and programs, to share your data with our partners, and to notify you of changes in our organization and activities.

 

How do we protect your personal data?

To ensure adequate protection of company and customer data, we apply all necessary organizational and technical measures provided by the Personal Data Protection Act.

The company has established rules to prevent misuse and security breaches and has appointed a Data Protection Officer to assist in preserving and ensuring the security of your data.

To ensure maximum security during data processing, transfer, and storage, we may use additional protection mechanisms such as encryption, pseudonymization, etc.

 

With whom will we share your information?

Our service providers (third parties), who perform certain tasks on our behalf and according to our instructions, may also have access to information related to the visitors of our website to the extent necessary to provide their services to us. These third parties include our IT service providers who perform tasks in hosting, database management, website management, maintenance services, alert services, web analytics, and handling incoming inquiries and data analysis.

Our website uses analytical tools provided by specialized third parties to help us diagnose technical issues, analyze traffic to our website, analyze trends, monitor and measure how our visitors engage with our website content.

Our service providers (third parties) and the analytical tool providers we use may access information related to your device, browser, and how you navigate our content according to this statement from different countries, including countries outside the European Union.

 

User Rights

Every user of the site enjoys all the rights to personal data protection under Bulgarian legislation and EU law.

The user can exercise their rights through the contact form or by sending a message to our email.

Every user has the right to:
- Awareness (regarding the processing of their personal data by the controller);
- Access to their personal data;
- Correction (if the data is incorrect);
- Deletion of personal data (right "to be forgotten");
- Restriction of processing by the controller or processor;
- Data portability between separate controllers;
- Objection to the processing of their personal data;
- The data subject also has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects them;
- The right to judicial or administrative protection if the rights of the data subject have been violated.

 

The user may request deletion if any of the following conditions are met:

- The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- The user withdraws the consent on which the processing is based and there is no other legal ground for the processing;
- The user objects to the processing, and there are no overriding legitimate grounds for the processing;
- The personal data have been unlawfully processed;
- The personal data must be deleted to comply with a legal obligation under Union or Member State law to which the controller is subject;
- The personal data have been collected in relation to the offer of information society services to children, and the consent is given by the holder of parental responsibility over the child.

If the user wishes to have their personal data deleted, they should send their request to the Data Controller via the email provided above.

 

The user has the right to restrict the processing of their personal data by the controller when:

- They contest the accuracy of the personal data. In this case, the restriction of processing is for a period that allows the controller to verify the accuracy of the personal data;
- The processing is unlawful, but the user does not want the personal data to be deleted, and instead requests the restriction of their use;
- The controller no longer needs the personal data for processing purposes, but the user requires them for the establishment, exercise, or defense of legal claims;
- They have objected to the processing pending verification of whether the legitimate grounds of the controller override those of the user.

 

Right to Data Portability

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format, and has the right to transfer those data to another controller without hindrance from the controller to whom the personal data have been provided, where the processing is based on consent or a contractual obligation and the processing is carried out by automated means. When exercising their right to data portability, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

 

Right to Object

Users have the right to object to the processing of their personal data by the controller. The data controller is obliged to cease processing unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims. If an objection is made to the processing of personal data for direct marketing purposes, the processing must cease immediately.

 

Complaint to the Supervisory Authority

Every user has the right to file a complaint against unlawful processing of their personal data to the Commission for Personal Data Protection or the competent court.

Term and conditions

 Terms of Use for the Website http://www.workingmama.coach

General Provisions

These general terms and conditions govern the relationship between "Working Mama" Ltd., hereinafter referred to as the "Merchant", and the users of the internet pages and services located on the website http://www.workingmama.coach, hereinafter referred to as "Users".

"Working Mama" Ltd. is a company registered under the Commercial Law of the Republic of Bulgaria with UIC 207605420, address ____, email address office@workingmama.coach, phone ________________.

Please read the published Terms of Use thoroughly before using the informational and commercial services offered on the Site (hereinafter referred to as "Services").

This document contains information about the activities of "Working Mama" Ltd. and the general terms of use for the services provided by "Working Mama" Ltd., governing the relationship between us and each one of our Users.

Confirming the Terms of Use is a necessary and obligatory condition for concluding the contract between the User and the Merchant.

By accepting the Terms of Use, the User agrees to have their personal data processed based on the contract concluded between them and the Merchant.

 Definitions

For the purposes of these general terms and conditions, the following terms shall have the meanings ascribed to them below:

- **Site**: http://www.workingmama.coach and all its subpages.
- **User**: any natural person who acquires goods or uses services not intended for commercial or professional activities, and any natural person who acts outside the scope of their commercial or professional activities as a party to this law.
- **Terms of Use**: these General Terms of Use, which include terms of use, cookies, registration and delivery rules, voluntary dispute resolution, contract cancellation and replacement forms, and any other legally significant information found on the Site.
- **Personal Data**: information about a natural person revealing their physical, psychological, mental, family, economic, cultural, or social identity.
- **Service**: any material or intellectual activity performed independently, intended for another person, and not primarily for the transfer of possession of a thing.
- **Service Agreement**: a contract, other than a sales contract, under which the merchant provides or agrees to provide a service to the user, and the user pays or agrees to pay for it.
- **Alternative Consumer Dispute Resolution Procedure**: a procedure for out-of-court resolution of consumer disputes that meets the requirements of this law and is carried out by an alternative consumer dispute resolution body.

#### Provided Services

1. On the Site, Users can conclude service agreements and have the services offered by the Merchant delivered.

Order

2. Users use the website interface to conclude contracts with the Merchant for the offered services.

   2.1. The service agreement is considered concluded from the moment the order is confirmed by the Merchant.

   2.2. In case a specific service cannot be performed, the Merchant reserves the right to refuse the order.

   2.3. After selecting one or more services offered on the Merchant's website, the User must add them to their purchase list.

   2.4. Upon ordering, the User receives a confirmation via email that their order has been accepted.

3. The Merchant has the right to refuse to conclude a contract with an incorrect User.

   3.1. The Merchant may treat a User as incorrect in cases where:

     - The User does not comply with the Terms of Use;
     - The User's behavior towards the Merchant's representatives is deemed inappropriate, arrogant, or rude;
     - Systematic abuses by the User against the Merchant are identified.

Prices

4. The prices of the offered services are those listed on the Merchant's website at the time of the order, except in cases of obvious errors.

   4.1. The prices of the services include VAT, where applicable.

5. The Merchant reserves the right to change the prices of the services offered on the site at any time and without notice. Such changes do not affect already placed orders.

6. The Merchant may provide discounts for services offered on the site according to Bulgarian legislation and rules determined by the Merchant. The rules applicable to such discounts are available at the place where the discount is displayed. Discounts may be provided in various forms (e.g., promotions, loyalty discounts, provided individually, randomly, or as a result of participation in a competition or customer survey).

   6.1. Different types of discounts cannot be combined when ordering and purchasing the same service.

Payment

7. If the User returns a service with the right to a refund for any reason, the amount subject to a refund is reduced by the value of the applied discount on the service, and only the amount actually paid is refundable.

8. The User can pay for the ordered services using one of the listed methods on the website. Payment on the Site is possible through the following methods:

   - Debit/credit cards, Stripe, and direct bank transfer

**Additional clarifications:**

   - The Merchant does not withhold any mandatory and/or additional fees or mandatory percentage of the payments made in its favor using debit/credit cards, PayPal, GooglePay, ApplePay, Stripe.

**Steps for payment via virtual POS:**

   - **Step 1: Filling in data**

     Upon loading the virtual POS page, the amount you have chosen to pay and fields for your bank card data will be displayed. Follow the description of the fields and enter the necessary data.

   - **Step 2: Confirming the payment**

     After filling in the required fields, you must confirm the payment by selecting the "Confirm" button at the bottom of the screen.

   - **In case of unsuccessful payment:**

     - If there are issues with your password for additional authentication, contact your card issuer.
     - For issues related to availability or technical problems with the card, contact your card issuer.
     - For other issues, contact us via the provided email and phone for contact.

   - **Step 3: After confirming the payment, you will receive confirmation for the ordered payment. This is the last step for making a payment via virtual POS.**

**Additional clarifications:**

   - The Merchant undertakes not to disclose to third parties the names and numbers of bank cards of the holder of an electronic payment document that became known in connection with the execution of the Contract and these Terms of Use.

   - The Merchant undertakes not to alter the data on the receipts/forms of processed payments with bank cards after the cardholder has received their copy of the receipt/form.

   - The Merchant cannot accept payments with bank cards for goods and/or services beyond those defined according to the subject of these Terms of Use.

   - The Merchant undertakes to accept payments with bank cards under the same conditions as bank transfers and not to charge additional fees and commissions to the prices of goods and/or services at the time of purchase, depending on the chosen payment method through a debit card.

   - With our payment partners (third parties), who need personal data to process a transaction you initiated: We have agreements with banks and other financial institutions for each payment method we offer. When you authorize a transaction, we transfer the necessary data to the relevant third parties to process the transaction. The required data varies depending on the payment method but may include your name, address, and details of the purchase you are trying to make.

9. If the User chooses a payment method involving a third party - a payment service provider, the User may be bound by the terms and conditions and/or fees of that third party.

10. The Merchant is not responsible if a payment method involving a third party - a payment service provider, is unavailable or otherwise does not function for reasons not attributable to the Merchant.

#### Withdrawal from the Contract and Replacement

11. The User has the right to withdraw from the contract without giving any reason, without owing compensation or penalty within 14 days from the date of conclusion of the service contract by the User.

12. To exercise the right under this clause, the User must unambiguously notify the Merchant of their decision to withdraw from the contract, specifying the goods/services they wish to return, by providing all data of the completed order and delivery, including but not limited to: content and value of the order, details of the person who placed the order, and more.

13. The Merchant publishes a form for exercising the right of withdrawal from the contract on its website.

14. For exercising the right of withdrawal, the Merchant provides the User with the option to fill out and send electronically through the website the standard withdrawal form or another unambiguous statement. In such cases, the Merchant immediately sends the User a confirmation of receipt of the withdrawal on a durable medium.

15. When the Merchant has incurred expenses related to the contract's execution and the User withdraws from the contract, the Merchant has the right to retain the corresponding amount for the incurred expenses or to require their payment.

16. The User has no right to withdraw from the contract if the subject of the same is:

    - The provision of services, where the service is fully provided, and its execution has begun with the explicit prior consent of the user and confirmation from them that they are aware they will lose their right of withdrawal once the contract has been fully executed by the merchant.

17. The Merchant refunds the amount paid by the User.

   17.1. If the user has made a payment under the contract with a bank card and has exercised their right of withdrawal, the refund is made by arranging a reverse operation on the card used for the payment within 7 working days.

 Complaints

18. The User has the right to complain about any non-conformity of the service with the agreed/ordered.

19. The User has the right to make a complaint about the service, regardless of whether the manufacturer or the merchant has provided a commercial guarantee.

   19.1. A complaint about services can be made up to 14 days from the

 discovery of the non-conformity of the service with the agreed.

20. Complaints about services can be submitted in one of the following ways:

   - On the telephone number provided by the Merchant;
   - By filling in the electronic form for complaints available on the Merchant's website;
   - By email at the provided email address.

21. When submitting a complaint, the User indicates the subject of the complaint, their preferred way of complaint satisfaction, respectively, the amount of the claimed amount, and address, telephone, and email for contact.

22. When submitting a complaint, the User must also attach the documents on which the claim is based, namely:

   - Receipt or invoice;
   - Protocols, acts, or other documents establishing the non-conformity of the service with the agreed;
   - Other documents establishing the claim based on grounds and amount.

23. The complaint is made by the User personally or by an authorized person.

24. The Merchant maintains a register of complaints. The User is sent a document to the email they have indicated, containing the number of the complaint from the register and the type of service.

25. When the Merchant satisfies the complaint, they issue an act for this, which is drawn up in two copies, and necessarily provide one copy to the User.

Personal Data Protection

26. The Merchant takes measures to protect the User's personal data according to the Personal Data Protection Act.

27. For security reasons of the User's personal data, the Merchant will send the data only to the email address that was indicated by the Users at the moment of registration.

28. The Merchant accepts and announces on its website a Privacy Policy.

29. The User agrees that the Merchant has the right to process their personal data necessary for the execution of orders in the e-shop and the performance of the contract.

30. The User agrees that the Merchant has the right to send at any time electronic messages to the User, including a newsletter or offers for the purchase of goods, unless the User has explicitly refused to receive such messages.

31. The User agrees that the Merchant has the right to collect, store, and process data about the User's behavior when using the e-shop services.

32. At any time, the Merchant has the right to require the User to legitimize and verify the accuracy of each of the circumstances and personal data announced during registration.

Amendments and Access to the Terms of Use

33. These general terms and conditions may be amended by the Merchant, of which the latter will appropriately notify all registered Users.

34. The Merchant and the User agree that any additions and amendments to these general terms and conditions will have an effect on the User after the explicit notification by the Merchant and if the User does not declare within the provided 30-day period that they reject them.

35. The User agrees that all statements of the Merchant regarding the amendment of these general terms and conditions will be sent to the email address indicated by the User during registration. The User agrees that emails sent according to this article do not need to be signed with an electronic signature to have an effect on them.

36. The Merchant publishes these general terms and conditions on its website, together with all additions and amendments thereto.

#### Intellectual Property

37. The User has no right to copy, store, distribute, or use textual content from the Merchant’s website without the explicit permission of the Merchant. 

38. The User has no right to use, distribute, copy, etc., intellectual property without the permission of the Merchant and/or respective rights holders.

 Termination

39. The contract between the parties is terminated upon the occurrence of any of the following circumstances:

    - Termination and declaration of liquidation or declaration of bankruptcy of one of the parties to the contract;
    - Mutual consent of the parties in writing;
    - Objective impossibility of any of the parties to the contract to fulfill its obligations;
    - In case of seizure or sealing of equipment by state authorities;
    - In case of deletion of the User's registration on the Site. In this case, concluded but unfulfilled service contracts remain in force and are subject to execution;
    - In case of exercise of the right of withdrawal according to these general terms and conditions.

 Force Majeure

40. None of the parties will be held liable for failure to fulfill their contractual obligations if such failure is due to force majeure. Force majeure is an unforeseeable event beyond the control of the parties which cannot be avoided.

41. If within 14 days from the occurrence of the force majeure event it does not cease, either party has the right to notify the other party that they terminate the contract without owing the other party compensation for any possible damages incurred.

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