USER PRIVACY NOTICE

Controller:

The Data Controller of this App is OS IMPLANTS Ltd., UIC 205559287, registered in the Republic of Bulgaria, hereafter reffered to as “We”, “Us” or “AR SKULL ANATOMY”.

This Privacy Policy regulates the data collection and processing in our App.

Contact details

You can contact us with any personal data related questions or requests at vezirov@oseducation.eu or by phone: +359 884 93 55 25

GROUNDS AND PURPOSES OF THE PROCESSING OF PERSONAL DATA

We process personal data only when one of the following applies:

  • There is concluded contract between you and us with the purpose to execute our contractual obligations;
  • We received explicit consent from you – the purpose is being specified for each case;
  • There is legal obligation for us to process the personal data;
  • The legitimate interest of the Controller

In this Privacy policy you will find detailed information regarding the processing of personal data.

PROCESSING OF DATA FOR THE EXECUTION OF CONTRACT OR DURING PRE-CONTRACTUAL RELATIONS

We process personal data to execute our contractual and precontractual obligations. The purpose of the processing is as follows:

  • To Identify the data subject
  • To provide our services and products
  • Prepare offers
  • Send you invoices/ bills for the services you are using
  • To provide you full support
  • To receive payments from you
  • To maintain correspondence with you
  • To prevent unlawful behavior or breach of our Terms of use and Privacy policy

Category of data subjects

On this legal basis we processe data of our clients. A client is any individual or representative of a company who has a contractual or pre-contractual relationship with us and wishes to use the provided Services.

Services

We provide educational services as described in our app or the App Store.

Data we process

On this ground, we process information regarding the type and content of the contract as well as any other information related to the contracted, including:

  • Username;
  • Personal contact data – contact email, name.
  • Information about the usage of the App such as whether a video tutorial was watched etc.

In order to execute our contractual obligations, we need the above information or the execution would be impossible without it.  Such personal data shall be marked in a specific way with a “*” or another sign. All other personal data is collected voluntarily.

Transfer of personal data to third parties

We transfer data to third parties with the purpose to improve the quality of our services and offer you full support. We only transfer personal data to third parties, who have proved to us they have applied or required organizational and technical security measures. In this case, we are responsible for the privacy and security of your data.

We transfer personal data to the following categories of third parties

  • hardware and software service providers
  • consulting service providers, such as lawyers, accountants, tax advisors and others
  • cloud service providers, such as AWS, Google, Microsoft etc.
  • communication applications such as Slack, Microsoft Teams, Zoom and others

Data deletion

We delete personal data processed on this ground after 5 years after the contract has expired regardless of the reason for the expiration. We chose this time period, because this is the expiration period for the claims from a contract.

We delete personal data collected during pre contractual relations after 12 months.

PROCESSING OF DATA IN COMPLIANCE WITH LEGAL OBLIGATIONS TO WHICH WE ARE SUBJECT

Sometimes there is a legal obligation for us to process personal data. In these cases we are obliged to process personal data. Such cases are:

  • Obligations under Measures against money laundry act (MAMLA);
  • Obligations under Consumer protection act (CPA)
  • Obligations to provide personal data to Consumer protection commission and third parties under CPA;
  • Obligations to provide personal data information to Personal data protection commission
  • Obligations under Accounting act and Tax-Insurance Procedure Code (TIPC)
  • Obligations to provide information to the court or third parties under the applicable procedure laws;
  • Obligation to certify the age of the data subject

Data deletion

Personal data processed on this ground is being deleted after the obligation has been fulfilled or has expired. For example under the Accounting act we must store the personal data 11 years.

Transfer of data to third parties

In case of legal obligation for us we could transfer personal data to third parties such as public authorities.

LEGITIMATE INTEREST

We collect and analyze data on the grounds of our legitimate interest. This data is collected in order to improve our services and client support. On this ground, we collect information regarding the performance of our App and the behaviour of our customers and analyze this data. Such data could be: anonymized IP address or session duration.

In case the collected data goes beyond our legitimate interest we would ask for your explicit consent.

Your data could be anonymized. Anonymisation is an alternative to data deletion. When the data is anonymized you could no longer be identified.

AFTER RECEIPT OF YOUR CONSENT

We process personal data on this ground only after your explicit consent. The consent is given in compliance with Art. 7 from Regulation 679/ 2016 (GDPR).

We do not foresee any negative consequences for you in case you decide not to share your personal data.

The consent is a separate ground for the processing of personal data and the purpose of the processing is specified for each case.

Processed data

On this ground we process only the data for which we have received your explicit consent. However, in most cases this data includes:

  • Email
  • Name

Transfer to third parties

On this ground we could transfer personal data to third parties, specified with the consent.

Withdrawal of the consent

The consent could be withdrawn at any time. The withdrawal does not in any way affect any contracts or other relations between you and us. The withdrawal does not affect the processing before the withdrawal was given.

To withdraw your consent you just have to use our App or write us an email.

Data deletion

We delete the data processed on this ground after receiving demand from you or 18 months from the initial processing.

Email marketing

In case you sign up to receive emails from us, you will receive messages with up-to-date information about our services, the services of our partners or other useful information. You can unsubscribe from the email newsletter by clicking the button in the email labeled “unsubscribe” or other similar text. You can also unsubscribe using our contact information provided in this Policy.

We use third party email marketing providers such as MailChimp or others.

DATA ANONYMIZATION

We process data for statistical purposes, which includes analyses in which the results are just general and thus the data is anonymous. It is impossible to identify a person from this data.

Your data could also be anonymized, which is an alternative of the data deletion. In this case all personal data elements, which allow the identification of a person will be permanently deleted. The anonymized data is not a personal data.

DATA PROTECTION

To ensure the protection of personal data of the company and the clients we apply all required organizational and technical measures under Data protection act and GDPR, as well as the best international practices.

We have adopted Rules for data processing in the company. To ensure maximum security we could apply additional protection measures such as pseudonymisation, encrypting and other.

DATA SUBJECT RIGHTS

You have all data protection rights under the Data protection act and GDPR.

You could use your right by contacting us through our website or just by writing us an email.

You have the right to:

  • Be informed regarding the processing of your personal data
  • Access your personal data
  • Demand correction your personal data
  • Deman deletion of your personal data
  • Demand limitation of the processing of personal data
  • Portability of personal data between the controllers
  • Object against the processing of personal data
  • Be excluded from fully automated decisions
  • Protect your right in court or through administrative procedure in case of violation of data protection rights

Data subject could demand deletion in the following cases:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
  • the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in 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 to a person under 16 years.

Data subject has the right to restriction of personal data, when:

  • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  • the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

Portability right.

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

  • the processing is based on consent or on a contract pursuant to point (b) of Article 6(1); and
  • the processing is carried out by automated means

Right to make a claim

Data subject has the right to make a claim against the unlawful processing of personal data to the Data protection commission or the according court. 

Personal data records

We maintain a record of our processing activities. This record contains the following information:

  • Name and coordinates of the controller
  • Purposes of the processing
  • Description of the categories of data subjects and processed data;
  • the categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations;
  • where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the documentation of suitable safeguards;
  • where possible, the envisaged time limits for erasure of the different categories of data;
  • where possible, a general description of the technical and organisational security measures referred to in Article 32(1).

Cookie Policy

Using “cookies”

Cookies are short text files or small bundles of information that are stored through the internet browser of your terminal device (PC, tablet, laptop or cell phone) when you visit different websites and pages on the Internet. The primary purpose of cookies is to make the Consumer recognizable when he returns to the website. Some cookies have a more specific purpose, such as storing Consumer behavior on the site and making it easier for the Consumer to use the website. More information on how cookies work can be found on the Internet.

How are cookies used on this Website?

We use cookies on this website primarily for facilitating the usability of the site, improving its work, and storing information about Consumer behavior. No personal data is stored in this process, ie. through the cookies of the site we can not identify you as a person, so the collection of this information does not apply to the Law for Protection of Personal Data. Collected information from cookies is typically used in a generic way to analyze Consumer’s behavior on the Website, which allows us to improve the functionality of the site, the Consumer paths, and the content we use.

Which cookies are used on this website?

Session cookies

This type of cookies makes it easier for you to use the site, and they store information temporarily only within the session of your browser. Typically, the information that is stored through them is what services you’ve added to your cart, which pages of the site you’ve visited, and how you’ve accessed some information. They do not collect any information from your computer and are automatically deleted when you leave the Website or end the session of your browser.

Persistent cookies

They enable us to store specific browsing information, such as analyzing site visits, how you’ve reached the Website, what pages you’ve reviewed, what options you’ve chosen, and where you’ve been targeting through this Website. Tracking this information enables us to make improvements to the Website, including bug fixes and content expansion. The shelf life of this type of cookie varies according to its intended purpose.

Third party cookies

Our site has links to other sites or embedded content from other sites, such as Facebook, YouTube, Twitter, Google+, LinkedIn, partner websites. It is possible that when visiting these sites or opening content from them, they will be stored on your terminal cookies from these websites. These cookies are defined as third-party cookies, and we have no control over the generation and management of these cookies. This is why we encourage you to search for information about them and how to manage the third-party websites.

How can I manage the use of cookies from this Website?

All browsers allow you to manage cookies from a specially designed folder on your browser. You can block the receiving of cookies, delete all or part of them, or set your cookie preference settings before initiating a visit to our site. Keep in mind that deleting or blocking cookies may adversely affect the functionality of our Website and, hence, your Consumer experience.

Disable or block cookies

Controlling, disabling, or blocking cookies is governed by your browser settings. Keep in mind

that a full ban on the use of all cookies may affect the site’s performance, its effectiveness, and access to certain information.

TERMS OF SERVICE

The current Terms OF SERVICE govern the relations between OS IMPLANTS Ltd., UIC 205559287, registered in the Republic of Bulgaria referred to as AR SKULL ANATOMY, on one part, and the Consumers (referred to as Consumers), on the other side.

Contact details

email: vezirov@oseducation.eu

phone: +359 884 93 55 25

Please, read entirely the published Terms of service before using the information and commercial services, provided by the App (referred to as Services).

The current document contains information about the activity of AR SKULL ANATOMY and the Terms of service, provided by AR SKULL ANATOMY, which govern the relations between us and each of our Consumers.

Confirmation of the Terms of service is an obligatory condition for concluding a contract between the Consumer and AR SKULL ANATOMY.

With accepting the Terms of service the Consumer is agreeing for his personal data to be processed on the grounds of the concluded contract between him and AR SKULL ANATOMY” in accordance with our Privacy Policy. 

DEFINITIONS

For the purpose of these Terms of service, the following Terms are to be understood as follows:

App Store – any store for mobile applications where the App is licensed and can be purchased.

Consumer – any natural person who, in relation to contracts covered by this Terms of Service, is acting for purposes which are outside that person’s trade, business, craft, or profession;.

Terms of service – the current Terms of service which include Terms of service, cookies policy, registration and delivery rules, voluntary dispute resolution, contract return form, guarantee form and any other legally relevant information.

Personal data – any information about an individual which reveals his or her physical, psychological, mental, family, economic, cultural or social identity.

Services – every material or intellectual activity, which is independently provided and is aimed at another person and does not involve transfer of goods.

Service Contract – a contract, which is NOT Sales contact and under which the Service provider has the obligation to deliver a Service to the Consumer and the Consumer has the obligation to pay the price for the Service.

Alternative Consumer Dispute Resolution- an out-of-court settlement procedure for Consumer

disputes that meets the requirements of the Consumer protection act and is executed by an alternative Consumer dispute resolution body.

  1. PROVIDED SERVICES
    1. AR SKULL ANATOMY offers free and paid educational services as described in the App and in the App Store.
  • USER REGISTRATION
    • AR SKULL ANATOMY identifies the Consumers by storing log files on the App’s server.
    • AR SKULL ANATOMY has the right to collect and use information about Consumers on the grounds and for the purpose of performing the contract concluded in Terms of service with the Consumer. The information by which the person can be identified may include names, address, email and phone number.
    • The information also includes any other information that the Consumer enters, uses or provides upon use of the App.
    • Only people over the age of 16 may register. By the sign up the person marks a checkbox indicating that he / she is over 16 years old.
    • When completing the application for registration, the Consumer is required to provide full and accurate data about the identity (for individuals) and the other required by the electronic form of AR SKULL ANATOMY data as and update them within 7 (seven) days of their change. The Consumer declares that he agrees to provide the required personal data, ensuring that the data he provides during the registration process is true, complete, and accurate, and will update them in a timely manner if changed by the latter. In the event of false data being provided, AR SKULL ANATOMY has the right to terminate or suspend without notice the provision of services as well as the maintenance of the Consumer’s registration.
  • PRICES
    • The prices of the services are these, listed in the App or in the App Store at the moment of the purchase.
    • The prices include VAT when the charging of VAT is applicable.
    • AR SKULL ANATOMY has the right to alter at any moment and without notice the prices of the offered services, taking into account that such changes will not affect already placed orders.
    • AR SKULL ANATOMY can give discounts for the services in compliance with the applicable legislation and the rules defined by AR SKULL ANATOMY. Discounts may be made in different variations (for example promotions, loyalty discounts, provided individually, randomly or as a result of participation in a competition or a client research).
    • Different types of discounts can’t be combined, unless otherwise provided.
  • PAYMENT
    • When the Consumer uses his right to get a refund for the sum paid for any reason, the price to be refunded shall be reduced by the amount of the discount received and only the amount actually paid shall be refunded.
    • The Consumer can pay the price of the ordered services directly from the App Store.
    • If the Consumer picks a method of payment, including a Third Party – provider of payment services, the Consumer may be obliged by the regulations and conditions and/or taxes of such a Third Party.
    • AR SKULL ANATOMY is not liable if a certain method of payment, including a Third Party – provider of payment services, is not available or in other aspect is not working due to reasons, for which AR SKULL ANATOMY can’t be held accountable for .
  • REMEDIES FOR THE FAILURE TO SUPPLY AND WITHDRAWAL
    • Where AR SKULL ANATOMY has failed to supply the digital content or digital service, the consumer shall call upon us to supply the digital content or digital service. If we then fail to supply the digital content or digital service without undue delay, or within an additional period of time, as expressly agreed to, the consumer shall be entitled to terminate the contract.
    • Article 5.1. shall not apply, and the consumer shall be entitled to terminate the contract immediately, where:(a) AR SKULL ANATOMY have declared, or it is equally clear from the circumstances, that AR SKULL ANATOMY will not supply the digital content or digital service; or (b) the consumer and AR SKULL ANATOMY have agreed, or it is clear from the circumstances attending the conclusion of the contract, that a specific time for the supply is essential for the consumer and AR SKULL ANATOMY fails to supply the digital content or digital service by or at that time.
    • The Consumer doesn’t have the right to withdraw from the contract, when the offered service is entirely digital and not available on durable medium and he was duly notified, that he would lose the right to withdraw from the contract with the beginning of the execution of the contract.
  • REMEDIES FOR THE LACK OF CONFORMITY
    • In the case of a lack of conformity, the consumer shall be entitled to have the digital content or digital service brought into conformity, to receive a proportionate reduction in the price, or to terminate the contract, under the conditions set out in this Article.
    • The consumer shall be entitled to have the digital content or digital service brought into conformity, unless this would be impossible or would impose costs on AR SKULL ANATOMY that would be disproportionate, considering all the circumstances of the case including: (a) the value the digital content or digital service would have if there were no lack of conformity; and (b) the significance of the lack of conformity.
    • AR SKULL ANATOMY shall bring the  digital  content  or  digital  service  into  conformity  pursuant  to  paragraph  2  within a reasonable time from the time AR SKULL ANATOMY has been informed by the consumer about the lack of conformity, free of charge and without any significant inconvenience to the consumer, taking account of the nature of the digital content or digital service and the purpose for which the consumer required the digital content or digital service.
    • The consumer shall be entitled to either a proportionate reduction of the price where the digital content or digital service is supplied in exchange for a payment of a price, or the termination of the contract in accordance with Article 6.7., in any of the following cases: (a) the remedy to bring the digital content or digital service into conformity is impossible or disproportionate in accordance with paragraph 6.2; (b) AR SKULL ANATOMY has not brought the digital content or digital service into conformity in accordance with paragraph 6.3; (c) a  lack  of  conformity  appears  despite  our  attempt  to  bring  the  digital  content  or  digital  service  into conformity; (d) the lack of conformity is of such a serious nature as to justify an immediate price reduction or termination of the contract; or (e) AR SKULL ANATOMY has declared, or it is clear from the circumstances, that AR SKULL ANATOMY will not bring the digital content or digital service into conformity within a reasonable time, or without significant inconvenience for the consumer.
    • The reduction in price shall be proportionate to the decrease in the value of the digital content or digital service which was supplied to the consumer compared to the value that the digital content or digital service would have if it were in conformity.
    • Where the contract stipulates that the  digital  content  or  digital  service  shall  be  supplied  over  a  period  of  time  in exchange for the payment of a price, the reduction in price shall apply to the period of time during which the digital content or digital service was not in conformity.
    • Where the digital content or digital service is supplied in exchange for the payment of a price, the consumer shall be entitled to terminate the contract only if the lack of conformity is not minor.
    • In the event of termination of the contract, AR SKULL ANATOMY shall reimburse the consumer for all sums paid under the contract. However, in cases where the contract provides for the supply of the digital content or digital service in exchange for a payment of a price and over a period of time, and the digital content or digital service had been in conformity for a period of time prior to the termination of the contract, AR SKULL ANATOMY shall reimburse the consumer only for the proportionate part of the price paid corresponding to the period of time during which the digital content or digital service was not in conformity, and any part of the price paid by the consumer in advance for any period of the contract that would have remained had the contract not been terminated.
  • MODIFICATION OF THE DIGITAL CONTENT OR SERVICES
    • AR SKULL ANATOMY may modify the digital content or digital service beyond what is necessary to maintain them. Such modifications shall be made without additional cost to the consumer after providing clear and comprehensive information to the consumer.
    • In the cases referred to in paragraph 7.3., the consumer shall be informed reasonably in advance of the features and time of the modification and of the right to terminate the contract in accordance with paragraph 7.3., or of the possibility to maintain the digital content or digital service without such a modification in accordance with paragraph 7.4.
    • The consumer shall be entitled to terminate the contract if the modification negatively impacts the consumer’s access to or use of the digital content or digital service, unless such negative impact is only minor. In that case, the consumer shall be entitled to terminate the contract free of charge within 30 days of the receipt of the information or of the time when the digital content or digital service has been modified by AR SKULL ANATOMY, whichever is later.
    • Paragraphs 7.2. and 7.3. of this Article shall not apply if AR SKULL ANATOMY has enabled the consumer to maintain without additional cost the digital service without the modification, and the digital content or digital service remains in conformity.
  • INTELLECTUAL PROPERTY
    • The rights of intellectual property over materials and resources, placed in the App (including the existing database), that are an object of protection under the Law on Copyright and Neighbouring Rights, are property of AR SKULL ANATOMY or the indicated person, who transferred the right of use to AR SKULL ANATOMY and cannot be used in violation of the current legislation.
    • When copying or reproducing information beyond the legal limits or by any other violation of intellectual property rights on the resources of “AR SKULL ANATOMY”, AR SKULL ANATOMY   has the right to make claim for all damages including direct and indirect damages.
    • Except as expressly agreed upon, the Consumer may not reproduce, modify, delete, publish, distribute or otherwise disclose the information resources available in the App.
    • “AR SKULL ANATOMY” is obliged to exercise due care to enable the Consumer to have normal access to the services provided.
    • “AR SKULL ANATOMY” reserves the right to stop access to the services provided. AR SKULL ANATOMY has the right, but not an obligation, at its discretion to delete information resources and materials posted in the App.
  • SEVERABILITY CLAUSE

The parties declare that if any of the provisions of these Terms of service prove to be invalid, this will not invalidate the entire contract or any of its parts. The invalid clause will be replaced by the mandatory rules of the law or established practice.

  1. AMENDMENT TO THE TERMS OF SERVICE
    1. “AR SKULL ANATOMY” is obliged to notify Consumers for any amendment to these Terms of service within 7 days of the occurrence of this circumstance at the email address specified by the Consumer.
    1. When the Consumer disagrees with the Terms of service, the Consumer has the right to withdraw from the contract without giving any reason and without being liable for damages or penalty. In order to exercise this right, the Consumer must notify“AR SKULL ANATOMY”  within one month of receiving the notice under the preceding paragraph.
    1. In case the Consumer does not exercise his right to withdraw from the contract in accordance with these Terms Terms of service, the Consumer shall be considered to have accepted the Amendment without objection.
  1. APPLICABLE LAW

The provisions of the law of Republic of Bulgaria shall apply to any cases unregulated under these Terms of service.