Private policy

Protection of Personal Data

Minerva Consulting Ltd., UIC 204276311, registered office and address for correspondence: Republic of Bulgaria, Pleven District, Levski Municipality, Malchika Street 51, postal code 5900 (hereinafter referred to as “Minerva Consulting” or “We”) is committed to protecting and respecting your privacy when you visit our website www.exceptional-woman.com (“the Website”), use our applications (“Applications”), other products or services referred to collectively as “Services” (the website, applications, other products, and services).

This Privacy Policy sets out how we manage the data and information that may directly or indirectly identify you (“Personal Data”) when you use our Services.

Please read our instructions for handling personal data carefully.

What personal data do we collect

Data voluntarily provided by you (the data subject):

By using our Services, such as creating an account, establishing a connection, viewing courses or programs, or participating in questionnaires, you will be asked to provide us with personal data.

This information includes, but is not limited to:

• Personal registration data with us, namely email address and password; and for paid services, additionally, your banking information;

• You may voluntarily provide additional information such as gender, age, first name, last name, profile picture, and address. Providing this additional information is not mandatory for registration with us, but it makes our connection more personal;

• Personal data that you send to us to contact us, specifically through the online contact form, including email address, the content of your inquiry, any attached files, phone number, etc. (if necessary to resolve an issue related to our services, we will ask you for additional information);

• IP address, device model, browser, and language of the device you use for the Services; (Copy of our correspondence (including email) in case it becomes necessary;)
• When you register, you agree to receive our promotional emails at the email address you provided. If you do not wish to receive promotional and marketing emails from us, follow the unsubscribe instructions. We will then remove you from our mailing list;
• Your responses to surveys to which you are invited, as well as the content of your posts on our website. This information may be used for user behavior analysis to help us improve our services;
• The personal information you provide when registering to participate in games or any of our sponsored promotions;
• Details of any transactions and orders made through our services.

We collect this data automatically

a. Personal data from social networks

When you log into our services through your Facebook profile, Instagram profile, Twitter profile, Pinterest profile, Google profile, we collect your email address, name, last name, gender, and username on Facebook, Instagram, Twitter, Pinterest, Google exactly as when creating your Facebook, Instagram, Twitter, Pinterest, Google account. We also have access to certain data in your Facebook, Instagram, Twitter, Pinterest, Google profile in accordance with the terms of use of that social network.

b. Data on the use of our services

Your consumption behavior is recorded in registration files. Our technical team uses the data collected from the registration files of all users to improve our services and understand how our services are used (e.g., number of course sessions, course duration, course history, etc.). This information is displayed in your user profile.

If you receive our newsletter in HTML version, we will be informed about the opening of the newsletter sent by email and will retain this information. Your clicks on the links in the newsletter are also recorded. Your clicks, together with the newsletter opening statistics, are aggregated in such a way as to obtain useful information about the popularity of the content, to make future content-related decisions, and to make adjustments to our program.

c. Cookies

During each of your visits, in accordance with applicable legislation, we may collect information through the devices you use to access our services or the networks through which you access our services, including your IP addresses, connection data, types and versions of internet browsers, operating systems and platforms, data about your navigation on our website and in our applications, download errors, content you have accessed, or advertising identifiers on your device, among others.

For this purpose, we use cookies.

What are cookies?

Cookies are text files containing information that are downloaded to your personal computer, laptop, or mobile device when you visit our website. Then, your browser sends the cookies back to the originating website on each subsequent visit or to another website that recognizes those cookies.

What cookies do we use?

We would like to provide you with the simplest, most practical, and secure access to our services. For this purpose, we use different categories of cookies with your consent:

• Strictly necessary cookies: These cookies allow you to navigate our website and applications and use essential features.
• Security cookies
• Identification cookies: These cookies save your user identification, so you don’t have to enter your username and password each time you use our website, applications, and services.
• User interface customization cookies: These cookies retain your personalized settings, such as preferred language and name.
• Analytical and performance cookies: These cookies allow us to see and record the number of visitors to our website and applications and gather information about their usage. This enables us to improve the functionality of our website, applications, and overall content of our services. These cookies allow us to analyze the effectiveness of our marketing campaigns.
• Social media sharing cookies: If you share any of our content on social media using the sharing button, a cookie may be placed on your device if you have given consent for this type of tracking.
• Advertising and targeting cookies: These cookies track your visits to our website, the pages you have visited, and the links you have followed. With this information, we can display ads that match your interests, limit the number of ads you see, and measure the effectiveness of advertising campaigns. They may be shared with third parties, such as advertising and media agencies.

We delete these cookies 13 months after your last consent.

Third-party cookies

Third-party providers, to whom we have entrusted the recording of our users’ behavior for advertising purposes, may use cookies that are beyond our control.

Our website uses Facebook Pixel, Facebook Analytics, and Google Analytics. For example, Google Analytics installs cookies to track the number of visitors to our website and the volume of usage to ensure our services are available at satisfactory speed at all times. Further information about how Google Analytics processes this information can be found at www.google.com/analytics.

We also use Google AdWords and Facebook Ads as part of our marketing activities. These services may install cookies on your device.

Cookies can also be installed if you go through us to a third-party website (e.g., YouTube videos) or use links to social media (e.g., “Share” button).

We have no control over how these third parties use cookies and how long they store them. Information about cookies from these operators can be found in their respective privacy policies.

What influence do you have on cookies?

During your first visit to the website or applications, we will inform you about this policy and ask you to decide whether to accept or reject the use of third-party cookies that we use for measuring the number of visitors and the effectiveness of our online marketing activities.

You can change your decision at any time by sending an email to [email protected].

Cookie settings can also be changed through your browser settings.

You can configure your browser to either automatically create cookies or prompt you for permission before storing a cookie on your hard drive. Of course, you can also choose to “not accept cookies.” Our services do not support browsers with the Do-Not-Track tracking feature enabled.

If you want to use all our features correctly, we recommend that you consent to cookies so that you can access the majority of our content and elements of our services.

How do we use your personal data?

We process your personal data for the following purposes, which are based on the legal grounds of fulfilling our contractual obligations and responding to your inquiries:

• To provide you with access to our services and deliver the necessary information and services (including gift cards).
• To assist our customers.
• To receive your payments.
• To inform you of changes.
• To enable you to use our interactive features if desired.
• To create an accurate report of the courses you have taken and statistics regarding your use of our services.
• To send emails related to the use of our services or provide advice/coaching that accompanies your course practices and motivation.
• To analyze the messages you have exchanged with other members of our community through the website or applications and ensure compliance with our terms of use.

The processing of your personal data is also justified by our legitimate interest, which has a legal basis in the following cases:

• Improving and optimizing our website and applications, specifically ensuring that the display of our content on your computer or other device is adapted.
• Administering our website and applications and implementing internal technical measures to address malfunctions, data analysis, testing, research, analysis, investigations, improvement, and ensuring the security of our website and applications.
• Generating statistics on your use of our services to provide content tailored to your needs and improve our services.
• Sending emails or SMS in accordance with applicable legal provisions for services similar to those you use or sending special offers to advertise our services.
• Managing statements, incidents, complaints, and disputes to protect our rights and defend them in court.
• Recording the results of our marketing activities to ensure the development and continuity of our activities.

Your personal data will also be processed to enable us to respond to your requests regarding your right to information, correction, objection, or other rights related to your personal data. This processing is based on compliance with our legal obligations.

The processing of certain cookies (see point 2 above) or the receipt of information from third parties by email or SMS is based on your consent, which you can withdraw at any time, provided that this is the only applicable legal basis.

Who will your personal data be shared with?

Personal data is processed internally by duly authorized persons within the scope of their competence.

They may also be shared with:

• Financial institutions that hold accounts.
• Competent administrative and judicial authorities, such as tax authorities, so that Minerva Consulting can comply with its legal obligations and agreements concluded with you, in such a way as to ensure maximum protection of its and your rights, guarantee the ownership and security of Minerva Consulting, our clients, and third parties, and fulfill its legal obligations.
• Legal advisors and debt collection officers.
• Any member of our group, i.e., our subsidiaries, the holding company, and its subsidiaries, to the extent necessary and with contractual guarantees to ensure the security and confidentiality of the data.
• Subcontractors (including IT service providers) and external service providers (e.g., auditors, legal advisors, trustees, system solution providers, or payment service providers, companies and organizations specialized in fraud protection and prevention of bad debts, etc.), to the extent strictly necessary and with contractual guarantees to ensure the security and confidentiality of the data.
• If you explicitly request it (e.g., if you use social media authentication methods or subscribe to a service provided by one of our partners), we may need to share your personal information with that partner to enable them to provide you with the desired services or information. The same third party is responsible for the legally prescribed use of your personal data, solely for the purpose of providing the requested service or responding to your inquiries.
• In the event that we sell or acquire a company or property, we may transfer your personal data to the potential buyer or seller to the extent necessary.
• In the event that Minerva Consulting or a significant portion of its assets is acquired by a third party, the Personal Information we have about you will be transferred to the recipient.

How do we protect your personal data?

Minerva Consulting, as the entity responsible for data processing, processes and uses the personal data it collects in accordance with applicable data protection laws, such as the Personal Data Protection Act, which entered into force on February 2, 2002, and the EU General Data Protection Regulation (GDPR) 2016/679.

Minerva Consulting is committed to implementing technical and organizational security measures to ensure the protection of personal data that is exposed to risks through the use of information systems, particularly by preventing unauthorized access to this information. Your personal data will only be used by us as stated in point 2 above when shared with third parties. Any other disclosure requires your explicit consent.

All your data is stored on secure servers in Bulgaria. All payment transactions are encrypted using SSL technology. If you have received a password from us for certain services (or if you have chosen one yourself), it is your responsibility to keep it confidential. We advise you to carefully consider whom you may share it with. Unfortunately, the internet is not a completely secure means of transmitting data. We do our best to protect your personal data, but we cannot guarantee its security. You transmit all data at your own risk.

How long do we retain your personal data?

Your personal data will be retained for a period of 10 (ten) years from the closure of your profile or the last use of our services, if you have not closed your profile, in accordance with the applicable period. If necessary, this period may be extended for the duration of ongoing judicial or administrative proceedings.

When you close your profile or, if you do not close it, two (2) years after the last use of our services, your personal data will be stored for archiving purposes in order to fulfill our legal obligations or, if necessary, to protect ourselves in court. They will not be disclosed to third parties or used in any other way.

Your rights regarding personal data

You have the right to the following information free of charge:

• Access to your personal data and their correction;
• Information on whether your personal data is being processed;
• Information about the purposes of the processing, the categories of data being processed, the recipients or categories of recipients to whom the personal data is disclosed;
• A copy of the personal data undergoing processing in a comprehensible form and all available information on the origin of the data.

You have the following rights within the limits defined by applicable rules and upon proof of your identity:

• To request the erasure of all or part of your data or to restrict their processing;
• To object to the processing of your data;
• To exercise your right to data portability.

You can exercise these rights by sending an email to the following address: [email protected]. We are available at this address to provide you with explanations regarding the content of your rights or how to exercise them.

You can access and modify your personal data at any time through your online profile.

You also have the option to lodge a complaint with a supervisory authority such as the Commission for Personal Data Protection (CPDP) in the event of breaches of provisions applicable to personal data protection.

You can ask us not to use your personal data for advertising purposes, for example by sending information about our services. To do this, simply follow the instructions in the “Opt-out” included in the advertising material you receive. Alternatively, you can always send us an email at [email protected] or withdraw your consent directly in your user profile.

Our website may have links to websites of our partner networks, advertising agencies, and commercial partners from time to time. If you have surfed on one of these links, please note that these websites have their own privacy policies. We are not responsible for how these websites process the information they collect when you click on their link. You should obtain information about the data protection provisions of these operators before submitting your personal data.

Protection of Children’s Data

Our services are directed towards individuals above the age of 18. Minors between the ages of 13 and 18 (or the age of majority in their country) (“minors”) also have the right to use our services. However, this must be done under the supervision and with the consent of their legal representatives. We rely on the fact that parents and guardians have explained to minors their rights and responsibilities arising from the terms of use of our services (“Terms”). If you, as a legal representative of a minor, allow them to use our services, you accept our privacy policy and our terms. Children under the age of 13 are not permitted to use our services. If you are under the age of 13, please do not attempt to access our services. If you believe that we have collected personal data from a child under the age of 13, please notify us at [email protected] so that we can delete such data.

Changes to Our Privacy Policy

Minerva Consulting reserves the right to modify or update this data protection statement and any other provisions at any time. Users of our services will be informed on the homepage of the website or the application about the publication of the modified or updated data protection statement. All changes will take effect immediately upon such publication. By continuing to use our services, you agree to the modified data protection provisions. Under certain circumstances (e.g., if we want to use your personal data for purposes other than those stated in the data protection policy at the time of data collection), we will inform you personally and/or request your consent if necessary.

Contact

We welcome questions, comments, and suggestions regarding our privacy policy, which you can send to [email protected].

This data protection statement is valid and was last updated on December 10, 2022.