Data Protection Policy

The e-learning platform "eduboom", hereinafter referred to as "the Platform", is owned by "Ucha.se" EOOD (hereinafter referred to as "Ucha.se", "the Service Provider", or "the Owner"), VAT No. BG202294245, with its registered office and management address in Bulgaria, Sofia, postcode 1407, 14 Srebarna Str., fl. 2, which acts as the personal data controller for data provided through the eduboom platform website. At eduboom, we understand how important it is to preserve the confidentiality of all user information and to protect it using the best available technological means. For this reason, we have adopted strict data protection procedures and rules. Please read the following information carefully, and if necessary, you may do so together with your parents/legal guardians.

This Privacy Policy complies with General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, hereinafter referred to for brevity as "the Regulation", aimed at protecting the use of personal data. According to the Regulation, "personal data" means any information about the user on the basis of which they can be identified. The Regulation refers to the use of the user's personal data as "processing", which may include not only the collection of personal data by us during the use of eduboom's services ("the Services"), but also any other action related to them.

Our Data Protection Principles

Lawfulness and Transparency

We process users' personal data lawfully, fairly, and in a transparent manner:

• a) for the purpose of fulfilling our obligations to the user when providing our services;
• b) with the user's consent, where necessary;
• c) for the lawful conduct of our business, implementation of innovations, and the seamless use of the platform's services;
• d) for other lawful purposes.

The user decides whether and how to use our services. The registration forms to be filled out contain mandatory fields, without which we will not be able to provide the respective service or part of it, but everything else depends on the user.

Right to Informed Choice

We always provide the user with accurate information and give them a choice regarding the type of personal data we receive from them, as well as the purposes and duration for which we collect and process it. We will not use the user's personal data for purposes incompatible with these principles, our Data Protection Policy, or the specific information related to our services.

Data Access

We provide easy access and the possibility to review, correct, amend, transfer, or delete the personal data provided to us.

Purpose Limitation

We use users' personal data solely for the purposes specified at the time of collection, as well as for other purposes compatible with them, in accordance with legal regulations.

Data Security

To protect the user's personal data from unauthorized use, we apply strict security measures to the information we hold and require the same level of security from our partners to whom we provide it for the fulfillment of our obligations to the user.

Accountability in Subsequent Data Transfer

We will share the user's personal data with third parties only if they undertake to provide the same level of protection as we do.

Purpose of Processing

The Controller collects personal data on eduboom in accordance with this Data Protection Policy and solely with the user's consent for the following purposes:

• Registration and purchase of a subscription providing access to the full content of the eduboom internet platform developed by the company "Ucha.se" EOOD;
• Promotion of services that are of interest to the user in the field of educational support: we may inform the user directly via marketing, newsletters, or surveys, email, SMS, by phone, etc. In this way, we can inform the user about similar or additional services, provide them with information about educational programs and projects, or other news that may interest them;
• Marketing and advertising: use of media channels and social networks for communication;

  Legal Basis: The legal basis for this type of processing is Art. 6 of the Regulation – our legitimate interest to inform the user about our services, both those used in the past and those they might be interested in or request in the future, taking into account the fact that in most cases we rely on their consent. The user can withdraw it in advance by sending an email for this purpose to dpo@eduboom.pl;

• For the purpose of protecting our legitimate interests – in cases where we must resort to protecting our rights and activities carried out to protect the Platform against fraud, personal data provided on the Site or collected automatically may be disclosed to state authorities in accordance with applicable legislation.

If we intend to process the user's personal data for a purpose other than that for which it was collected, we will provide them with information about that new processing purpose, as well as any other important information the user requests, such as:

• the period for which the personal data will be stored, in accordance with the criteria used to determine that period;
• the right to request information about their personal data, access to it, its rectification or erasure, restriction of processing, or the right to object to processing, as well as the right to data portability;
• the right to withdraw consent to the processing of personal data for one or more specific purposes at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• the right to lodge a complaint with a supervisory authority;
• whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the user is obliged to provide these personal data and what the potential consequences of failing to provide them might be;
• the existence of automated decision-making, including profiling.

How We Use the User's Data

Eduboom collects and uses users' personal data to fulfill its obligations to them as users of our services. Here are a few examples of how we do this:

Under the Contract Concluded Between Us

We use the user's personal data to fulfill our obligations as a provider. We need this data to maintain active communication with the user regarding our services. We use the user's data primarily to offer lessons tailored to their needs. To enable the use of the eduboom website, we store accurate contact, registration, and subscription purchase information, within which we provide full support to Users, offer Services and features they are interested in, allow participation in rankings and task performance, and conduct communication related to the subscription service (e.g., expiration reminders, automatic renewal confirmations, etc.).

Protection of User Identity

We take care of the security of the information stored with us. When interacting with us, we undertake to take reasonable steps to verify the user's identity, such as username and password, before granting them access to their personal data.

Advertising

We present the user with promotional offers based on their interests in eduboom services. This may include automated data collection tools. We may share some of the user's data with marketing service providers and digital marketing networks to show the user advertisements that may interest them.

What Data We Collect

The personal data we collect from the user depends on the services they use and may include the following elements:

Information Provided Directly by the User

• Contact details (such as first and last name, phone number, email address, password, user type, agreement with our Terms and Conditions and Personal Data Protection Policy). If the profile is of the "student" type, specifying a school grade is required. If the profile is of the "teacher" type, specifying the subject and the grade in which classes are taught is required.
• User activity on the platform – number of logins to the site, video materials watched, and tests solved.
• Payment-related data – information regarding transactions performed, order number, payment status, payment method used, as well as part of the data provided by the payment operator (e.g., first and last name, email address, payment identifier). These data are processed solely for the purpose of executing and confirming the payment, managing the subscription, and processing potential refunds. The legal basis for data processing is Art. 6, para. 1, b. "b" of the GDPR (RGPD/RODO), i.e., the necessity of processing for the performance of a digital services contract to which the User is a party.
• Secure access data: we collect usernames, passwords, registration passwords, and other similar security information related to authentication and access to user profiles.
• Preferences: we collect information about the user's preferences and interests regarding our services (based on what the user shares with us and inferences we make based on the data provided by them) and about their preferences to receive communications from us aimed at improving the services we provide.
• Social media data: We offer social media features that allow the user to share information on social networks and communicate with us through various social media sites. The use of these features may result in the collection and sharing of information about the user by us, depending on the feature. Therefore, it is important for the user to be familiar with the privacy policy and settings of the social networks they use.
• Other uniquely identifying information – for example, information provided to us in person, online, by phone, by mail, or through other customer service channels, responses to user surveys or contests, as well as additional information we collect to facilitate the provision of our services and respond to user inquiries.

Remember that you are under no obligation to share the personal data we need, although in some cases, if you choose not to share this information, we may not be able to provide you with our services, certain specialized features, or effectively respond to your requests.

Information Collected Automatically During the Use of Our Services

• Information about the user's visits and actions on our website, including content viewed and used. Part of this information is collected using our automatic data collection tools, which include cookies and web beacons.
• Anonymous responses to survey questions or general information about how our services are used. In the course of our work, we apply a process of de-identification or pseudonymization of data to minimize the likelihood of the user being identified through these data using available technologies.

Information from Third Parties

We receive information from third parties that we consider reliable and that is publicly available. To offer certain services at a corporate level, we may obtain the contact details of the user's company from a specific employee of the organization or school. If necessary, we may use the information provided by the user or their employer, along with information from publicly available and other online and offline sources, to contact the user regarding the services we offer.

We collect the user's personal data when they use our services or when they communicate with us via phone, email, and other available means of communication.

How We Protect Your Data

At eduboom, we have implemented reasonable technological and administrative measures to protect the personal data we process, ensuring that unauthorized persons do not have access to it, preventing data leaks, and guaranteeing that data is used correctly, lawfully, and for the period during which it is legally required by us.

How We Share Data

We share users' personal data solely in the following ways:

Sharing with Service Providers

We use the services of providers who perform certain activities on our behalf. These service providers may be located in countries of the European Union and the European Economic Area, as well as in the USA or other countries around the world, and may offer services such as credit card payments, customer service, order fulfillment, products, content personalization, IT services, email service providers, and data hosting. Our service providers are bound by our legal relationships and regulations to store the personal data received from us and are not allowed to use it for purposes other than providing services in accordance with our instructions.

In connection with the processing of subscription payments, we may transfer a limited amount of personal data to payment service providers (e.g., payment card operators, online payment systems, banks) – solely to the extent necessary for the execution and confirmation of the payment.

All such providers are bound by contractual obligations to process personal data solely in accordance with the Controller's instructions and in compliance with the requirements of the General Data Protection Regulation (GDPR).

Business Transactions

If at any point eduboom decides to restructure its business, we may disclose or transfer personal data to potential buyers or receive personal data from sellers, and it is our obligation to ensure appropriate protection of personal data in this type of transaction.

Compliance with the Law

We may share the user's personal data if we are required to do so in order to:

• (a) respond to duly authorized information requests by law enforcement authorities and comply with national security and other law enforcement requirements;
• (b) comply with any laws, regulations, subpoenas, or court orders;
• (c) conduct investigations and assist in preventing security threats, fraud, or other criminal or malicious activities; or
• (d) protect the rights or personal safety of our employees and third parties in accordance with applicable legislation.

How to Get More Information from Us

• In the "Settings" menu, you can select the option to receive additional information from us by email;
• If you have requested to receive such communications, you can opt out of the subscription by disabling the service in "Settings".

Advertisements and Offers on Third-Party Websites

Eduboom advertises on websites owned by third parties. Sometimes this is done by sharing personal data using automated data collection tools.

We also use and allow advertising networks and other third parties to use cookies and other automated data collection tools to determine how the user interacts with our website, communications, and services, as well as with certain partner sites, and also for the purpose of identifying interests, creating profiles and interest segments to provide the user with the most useful and relevant Services. More information can be found in the section "How eduboom uses automatic data collection tools".

How We Use Automatic Data Collection Tools

We use and allow other companies to use cookies, web beacons, and other similar technologies ("automatic data collection tools") in connection with our services. We do this to understand how the user uses our services and to improve the user experience. More information about automatic data collection tools can be found at: www.allaboutcookies.org.

What are cookies?

Cookies are computer text data stored in the user's browser and used by websites. This data allows the identification of the user's device and the correct behavior of the website in accordance with their individual preferences. Cookies usually contain the name of the website, their storage time on the end device, and a unique number.

How do we use cookies?

eduboom uses cookies to adapt page content to user preferences and optimize site use. Through them, we also create anonymous statistical data (about user behavior on the site) to improve the structure and content of the site. Our goal is for eduboom to provide optimal results tailored to your needs.

What cookies do we use?

Within eduboom, two types of cookies are used: "session cookies" and "persistent cookies". Session cookies are temporary files that remain on the user's device until they leave the website or turn off the software (web browser) they are using. Persistent cookies remain on the user's device for the time specified in the parameters of the cookies themselves or until they are manually deleted by the user.

Cookies and Personal Data

Personal data collected through cookies can be used solely to perform certain functions related to the website user. Personal data is encrypted to prevent access to it by unauthorized persons.

Deleting and Rejecting Cookies

If the user does not wish to allow cookies at all or if they want to use only some of them, they should check their browser settings. Through browser settings, you can withdraw your consent to the use of cookies at any time, as well as delete cookies that have already been accepted. The "Help" section in the browser menu or the website www.allaboutcookies.org contains detailed information about the process of disabling cookies in various browsers.

Please note that disabling some cookies may limit access to certain features and parts of eduboom's content.

To disable tracking by Google Analytics on our websites, you must use http://tools.google.com/dlpage/gaoptout. If you want to disable third-party cookies related to interest-based advertisements, visit the page www.youronlinechoices.eu/pl.

What are web beacons?

Web beacons are transparent graphic images (usually 1 pixel x 1 pixel) embedded in online content, videos, or emails that allow the server to read certain types of information from the user's device, such as the time of viewing specific content or a specific email.

When do we use web beacons

We use and allow selected third parties to use web beacons (usually in combination with cookies) to collect information regarding the use of our website, interaction with emails or other means of communication, measure effectiveness, and provide appropriate content and messages. For example, we may include web beacons in emails or newsletters to determine whether our messages have been opened, whether actions have been taken, and whether our correspondence tools are working properly.

Disabling web beacons

Since web beacons are the same as any other content requested when generating a web page, they cannot be rejected or disabled. You can disable web beacons in emails by not downloading the images contained in received messages (this feature depends on the email software used on your computer). Note that this action will not always take precedence over web beacons or other ways of automatically collecting data from emails due to specific features of email software.

More information on this matter can be found in the information provided with your email software or by your service provider. Under certain circumstances, web beacons can be stopped by turning off cookies or changing cookie settings in the browser.

Exercising Your Rights and Contacting Us

The user has the right to access all personal data they have provided to us or that we store about them. The user also has the right to request rectification, completion, restriction, porting, or erasure of their personal data, as well as to request explanations regarding its processing. In some cases, the user's request may be rejected based on legal regulations, for example, when providing such information involves disclosing another person's personal data or when a statutory prohibition on disclosing such information exists.

Right of Access

The user may request confirmation from us as to whether we process their personal data and, if so, request access to it. This can be done by sending an application to us at the email address or physical address specified below.

Right to Rectification

The user may request us to correct inaccurate personal data related to them or to supplement the data we already have.

Right to Object

If we process your data based on our legitimate interest, you have the right to object at any time to the processing of these personal data for that specific purpose.

Right to Erasure (the "Right to be Forgotten")

You can delete your profile and associated personal data by sending an email to contact@eduboom.com, without needing to state a reason. Once the erasure is carried out by our team, your profile and all related personal data will be permanently deleted from our systems, unless legal regulations impose an obligation for their further storage.

Right to Restriction of Processing

The user may request us to restrict the processing of their personal data. In this case, the respective data will be marked and can be processed by us only for certain purposes.

Right to Data Portability

Under certain circumstances, the user may have the right to receive the personal data they have provided to us in a structured, commonly used, and machine-readable format (e.g., in digital format) and request the transfer of these data to another person without hindrance from us, provided that such transfer is technically feasible.

Right to Lodge a Complaint with a Supervisory Authority

If you believe that your rights regarding personal data have been violated, please contact us so we can understand how to resolve this matter. You can also contact your local data protection authority and lodge a complaint with them, especially if you live in an EU country or at the place of the alleged violation.

In Bulgaria, this is the Commission for Personal Data Protection:

• Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
• Website: www.cpdp.bg
• Email address: kzld@cpdp.bg
• Tel: 00359 2 9153518

Contact Us

At eduboom, we value your opinion. If you have any questions or concerns about our Privacy Policy, the collection and use of your personal data, or about a possible breach of privacy protection legislation, you can contact us at:

• Email address: dpo@eduboom.pl
• Address: Sofia 1407, 14 Srebarna Str.

Changes to Our Privacy Policy

If we make changes to our Privacy Policy, we will post the updated text here and indicate the date of the last modification. If the changes are material and significantly alter our privacy practices, we will notify the user by other means, such as by email or by posting a notice on our website and/or our social media pages, before the changes take effect. This Privacy Policy was published on the website in 12/2025.

This Privacy Policy does not apply to any third-party applications, products, services, websites, or social media features that are accessible through links provided by our site for the user's convenience. We encourage you to familiarize yourself with the privacy policy of every website visited before allowing it to collect information.