Privacy Policy

1. Introduction

Interactive Bulgaria Foundation (IBF, “we”, “our” or “us”), a non-profit organisation registered in Bulgaria (National ID 176889119) and located at ul. "Nikolay Ostrovski" 5, Sofia, Bulgaria, operates the Study360 platform (“the Platform”). This Privacy Policy explains how we collect, use, share and protect personal data when you use the Platform. IBF is the data controller responsible for processing personal data under this Policy. If you have questions, contact us at ibfprojectbg@gmail.com or call +359 877 366 209.

2. What Information We Collect

According to privacy-law guidance, a privacy policy should specify what information is collected. We collect the following categories of personal data:

2.1 Information You Provide Directly

  • Account information: To create an account you must provide a username and password or connect a Google account. You may also provide your name and email address.
  • Profile details (optional): You can optionally upload a profile picture and share a short biography (“About me”), Facebook link, LinkedIn link or other social media information.
  • User-Generated Content: Panoramic images and videos that you upload and any lesson materials or comments you create. Please avoid uploading personal data about others without their consent.

2.2 Information We Collect Automatically

  • Usage data: Information about your device and how you interact with the Platform, such as IP address, browser type, device type, pages viewed, and timestamps.
  • Cookies and similar technologies: We may use cookies to remember your preferences, maintain your session and gather analytics. A privacy policy should describe whether you collect data through cookies or trackers. You can adjust your browser settings to refuse cookies, but this may affect the functionality of the Platform.

2.3 Information from Third Parties

If you register through Google, we receive basic account information from Google (name, email, profile picture) as permitted by your settings.

3. How We Use Your Information

Privacy policies should explain why you collect personal data and how it will be used. We use your data for the following purposes:

  1. Providing and maintaining the service: To create and manage your account, display uploaded content, enable you to create and participate in lessons and allow others to view public content.
  2. Moderation and safety: To review uploaded content for quality and compliance with our Terms, detect and prevent abuse or illegal activity, and enforce our rules.
  3. Communication: To send you administrative messages (for example, account notifications, updates about changes to the Platform, or responses to your inquiries).
  4. Improvement and analytics: To understand how the Platform is used, fix errors, develop new features and improve user experience. Any analytics will use aggregated or pseudonymised data where possible.
  5. Legal compliance: To comply with obligations under the law and respond to requests from competent authorities.

We will only process personal data for the purposes described above or other purposes disclosed to you at the time of collection and will obtain additional consent if we intend to use your data for a different purpose.

4. Legal Bases for Processing

Under the General Data Protection Regulation (GDPR), we rely on the following legal bases to process personal data:

  • Consent: When you voluntarily provide information, such as optional profile details or uploading content.
  • Contractual necessity: To provide you with access to the Platform and fulfil our obligations under the Terms and Conditions.
  • Legitimate interests: For analytics, security and improving our services. We balance our interests with your rights and freedoms.
  • Legal obligation: To comply with applicable laws and regulations.

5. Sharing Your Information

Privacy policies should identify third parties with whom data may be shared. We share personal data in the following circumstances:

  1. Service providers: We use trusted third-party service providers for hosting, data storage, analytics and email delivery. These providers process data on our behalf and are contractually bound to protect your information and use it only for the services they provide to us.
  2. Legal requirements: We may disclose personal data if required by law, court order or other legal processes; to enforce our agreements; or to protect the rights and safety of IBF, our users or others.
  3. Project reporting: Because the Platform is financed by an Erasmus+ project, we may need to provide aggregated statistics (e.g., number of users, number of lessons created) to project funders. These reports do not include personally identifiable information.
  4. Change of control: If IBF or the Platform is involved in a merger, acquisition or asset sale, personal data may be transferred as part of that transaction, provided the receiving party agrees to honour this Privacy Policy.

We do not sell personal data or use it for advertising. We will not share your personal data with third parties for marketing purposes without your consent.

6. International Transfers

Our servers are located in the European Union. If we transfer personal data to countries outside the EU/EEA, we will ensure appropriate safeguards such as standard contractual clauses or adequacy decisions, as privacy law guidelines suggest.

7. Data Security

A privacy policy should describe how data is protected. We implement technical and organisational measures designed to protect your personal data against unauthorised access, alteration, disclosure or destruction. These include encryption, secure servers, access controls and regular monitoring. However, no method of transmission over the Internet or storage is completely secure; therefore, we cannot guarantee absolute security.

8. Data Retention

We keep personal data only as long as necessary for the purposes for which it was collected or as required by law. For example:

  • Account information is retained while your account is active.
  • Content you upload remains on the Platform until you delete it or your account is deleted, after which it may persist in backups for a limited period.
  • Log data and analytics may be retained for a limited time to improve and secure the Platform.

After these periods, data is deleted or anonymised.

9. Your Rights

Depending on your jurisdiction (e.g., under the GDPR), you may have rights regarding your personal data, including:

  • Access: The right to obtain confirmation of whether we process your data and a copy of that data.
  • Rectification: The right to request corrections to inaccurate or incomplete data.
  • Erasure: The right to ask us to delete your personal data under certain circumstances (also known as the "right to be forgotten").
  • Restriction: The right to restrict how we process your data.
  • Portability: The right to receive your data in a structured, commonly used format and transfer it to another controller.
  • Objection: The right to object to processing based on legitimate interests.
  • Withdraw consent: Where you have given consent, you can withdraw it at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at ibfprojectbg@gmail.com. We may ask you to verify your identity before processing your request. You also have the right to lodge a complaint with your local data protection authority.

10. Children's Privacy

The Platform is intended for users aged 13 and over. We do not knowingly collect personal data from children under 13. Privacy regulations require special protections for children's data. If you are a parent or guardian and believe your child has provided personal data to us without consent, please contact us so we can delete the information.

11. Third-Party Links

The Platform may contain links to third-party websites (e.g., Facebook, LinkedIn). We are not responsible for the privacy practices or the content of these sites. We encourage you to read the privacy policies of any website you visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on the Platform with a "Last updated" date. If we make material changes, we may notify you via email or through the Platform. Your continued use of the Platform after the effective date of any changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions or concerns about this Privacy Policy or wish to exercise your rights, please contact us at:

Interactive Bulgaria Foundation (IBF)
Address: ul. "Nikolay Ostrovski" 5, 1113 Sofia, Bulgaria
Email: ibfprojectbg@gmail.com
Phone: +359 877 366 209

By using the Study360 Platform, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.