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Privacy Policy of Circle4Care

Adopted on 26th of May 2025

Privacy Policy

About us 

Circle4Care is a mobile software application (“The Application”) which can be downloaded and installed on a smartphone or tablet (“The Device”). The operator of the web-module https://app.circle4care.org is a company registered in Bulgaria with the name AZPM Ltd., UIC 208275146, with address for correspondence purposes in the city of Veliko Tarnovo, Str. “Vastanicheska” 57, Floor 1, referred to as Circle4Care for the purposes of this Privacy Policy, is a personal data administrator and is responsible for the observance of the provisions of the General Data Protection Regulation 2016/679 and the Law on personal data protection, in force since 1/1/2002. This Privacy Policy seeks to inform about the personal data that Circle4Care processes through the managed mobile application, for what purposes, to whom it discloses them, what the rights of the users of the Application are with regard to the personal data processed and how they can be exercised. Circle4Care strives to provide accessible and useful information by means of an existing information website with videos and other information about the Application and its different functionalities.  

  1. About the Application

1.1. By developing the mobile application Circle4Care offers a single software technological solution that will assist elderly people and people in need of additional care (Family Bond) to continue leading a relatively independent life while, at the same time, their health and well-being will be tracked and remain under the supervision of a close family circle and the person who provides care (Assistant), if any. In this manner, the Application makes it possible to share information within a closed circle of people. 

1.2. The Family Admin creates, through the web module, a space (Circle) for the persons who will be using the application (Users) and sends an invitation for installation of the Application to each one of them. The Circle is a space for the persons who will be using the Application (Users) and consists of a Family Admin and the participants invited by him/her. The number of participants in the Circle is established and described in the different subscription plans (if subscription applies). The Family Admin is the person who chooses which subscription plan to pay for (if a subscription is due).

A circle of people who can use the Application includes the following roles: Family Admin, Family Bond, Family Members and Assistant (if any). 

By itself, the Application will support both the Assistant and the persons from the Circle while caring for the Family Bond, through optimization, better organization and traceability of the process itself.

1.3. The main information shared by the participants in the Circle is entered by the Family Admin. This information relates to:

1.3.1. The state of the health, namely, information regarding chronic diseases, dietary requirements, favourite foods and other details regarding the Family Bond;

1.3.2. A list of medicines that the Family Bond should take – dosage and other information added by the Family Admin and related to the intake of medication;

1.3.3. A list of planned doctor appointments, containing information added by the Family Admin concerning the date, hour, place, contact and a doctor who will perform it;

1.4. Among the participants in the Circle information is shared also concerning:

1.4.1. Personal data, such as names, sex, date of birth, etc. of the separate categories of Users;

1.4.2. Photographs selected according to the interests of the Family Bond, as well as such in which he/she participates, which can be organized in albums or shared in the form of Stories in pictures, including comments of the persons from the given Circle;

1.4.3. YouTube videos uploaded in the Application by the Family Admin, the links to which the Family Bond will be able to access. 

1.5. The Application supports three modes combined in one application and it is possible to share information about the Family Bond among them. The Application can be downloaded from Google Play and App Store.

1.6. As provider of the Application for its use by the Users in each of the three modes, Circle4Care is an administrator of data which it processes in relation to the registration of the User in the Application and its operation. 

1.7. The data which the Family Admin of the given Family Circle enters about him/herself and each one of the remaining Users, as well as the data which the separate Users enter about themselves, are stored by Circle4Care and visualized as they were entered.

1.8. In order to provide the capabilities described above, Circle4Care enters into a legal relationship with the Application Users who, depending on the mode and purposes of its use, have to be classified as part of a specific User category. The Users have to be distinguished from the Visitors.

  1. Personal Data Processed. Purposes of the Processing of Personal Data.

2.1. The personal data which Circle4Care collects from the Users depends on the mode of the Application used by the given User.

The information can be:

2.1.1. information provided directly by the User;

2.1.2. information which we collect automatically when the User uses the Application;

2.1.3. information from third parties.

2.2. Summary information provided directly by the User:

2.2.1. information for feedback to the User (for example: name, address, phone number, email address and other similar contact data);

2.2.2. account data – information on how the User buys or registers to use the Application, as well as other information related to the user’s account;

2.2.3. protected access data – user identifiers, passwords, password hints and other similar safety information is collected, related to the authentication and access to accounts of the user;

2.2.4. demographic data – for example, the country where the User lives, sex, age, children, etc.;

2.2.5. preferences – information is gathered on the preferences and interests of the User in relation to the use of the Application (from that which the user shares with us and from the conclusions we draw based on the provided facts) and the User’s preferences on receiving messages from Circle4Care, in order to improve the service provided.

2.2.6. other unique identifying information – for example, data which the User provides during personal contact, online, on the telephone or by mail or other channels for assisting users, answers to questions and user surveys or competitions, as well as additional information collected by Circle4Care to facilitate the provision of its services and to answer to the user’s inquiries.

2.3. Please pay attention to the fact that the User is not obliged to share his/her personal data requested by Circle4Care, although in some cases, if he/she chooses not to share this information, Circle4Care will not be able to provide its services to the User, certain specialized functions or answer effectively to the user’s inquiries.

2.4. According to the personal data processing purposes the different categories of Users and Visitors can be as follows:

2.4.1. Natural Persons in need of care (Family Bond):

The Natural Person – Family Bond is a user of the Application information on whose personal health will be shared by means of the Application between the Family Bond him/herself, his/her Family Members, and the Assistant (if any). The profile of the Family Bond is created by the Family Admin. The Family Bond installs the Application on a device and sees the entire information about him/herself which was entered by the Family Admin, but cannot change it.

For registration purposes, to install and use the Application and its functionalities, Circle4Care collects some or all of the following personal data of the Natural Person – Family Bond, which are stored by us and are visualized the way they were entered:

  • name;
  • sex:
  • profile picture/avatar;
  • telephone number /contact number;
  • IP address;
  • address;
  • date of birth and age (automatically calculated);
  • family relation with the Family Admin/ Family Members; 
  • local time calculated based on the address;
  • medical information/Health data concerning: 
  • illnesses, including chronic diseases;
  • medicines subject to ingestion (ingestion/dosage and other information);
  • time and conditions for medicine ingestion;
  • general practitioner (name, practice address, and two contacts);
  • date and hour of doctor appointments, which doctor will perform them (including previous and planned examinations);
  • dietary requirements;
  • favorite foods and drinks;
  • other photographs;
  • other details and information concerning the state of health, physiological needs, habits and preferences.

2.4.2. Natural Persons who are the administrators of a family (Family Admin):

The Natural Person – Family Admin is a person from the family who creates his/her user profile in the Application and pays a monthly or yearly subscription fee for its use (if a subscription applies). Through the web module of the Application, the Family Admin forms a Circle of the persons who will be using the Application and sends an invitation to each one of them. The Family Admin creates profiles for the Family Bond and the Assistant (if any) in which he/she enters all the information about them. He/she also sends an invitation to the Family to install the Application by entering their email address, including data about their family relation with the Family Bond.

For registration purposes, to install and use the Application and its functionalities, Circle4Care collects some or all of the following personal data of the Natural Person – Family Admin, which are stored by us and are visualized as entered:

  • name;
  • profile picture/avatar;
  • password (encrypted);
  • telephone number /contact number;
  • email for contact;
  • IP address;
  • address;
  • family relation with the Family Bond; 
  • local time calculated based on the address;
  • other photographs.

2.4.3. Natural Persons – Family Members:

The Natural Person – Family Member is a User of the Application who has family or other ties with the Family Bond. The profiles of the Family Members are created by the Family Admin who inputs their email addresses and family relation with the Family Bond. After that, the Family Admin sends by email an invitation to the Family to install the Application. After they download and install the Application on their Device, the Family can supplement the information about them. The Family Member do not have access to change the information on the Family Bond, they can only see it. They can share photographs and Stories in photographs.

For registration purposes, to install and use the Application and its functionalities, Circle4Care collects some or all of the following personal data of the Natural Persons – Family Member, which is stored by us and visualized as entered:

  • name;
  • profile picture/avatar;
  • password (encrypted);
  • telephone number /contact number;
  • email for contact;
  • IP address;
  • address;
  • family relation with the Family Bond; 
  • local time, calculated based on the address;
  • other photographs. 

2.4.4. Natural Persons who are carers (Assistant):

The Natural Person – Assistant is a user of the Application who was invited by the Family Admin as an assistant of the Family Bond. The profile of the Assistant is created by the Family Admin. The Family Admin inputs information on the Assistant and sends him/her an invitation to install the Application. The Assistant installs the Application on his/her device and sees the information about him/her as entered by the Family Admin. This information is also visible for the other participants in the Circle. The Assistant has access only to the information on the Family Bond which was added by the Family Admin. The Assistant can add photos, but cannot see the photos and the Photo stories added by the Family Members and the Family Admin.

For registration purposes, to install and use the Application and its functionalities, Circle4Care collects some or all of the following personal data of the Natural Person – Assistant, which are stored by us and are visualized as entered:

  • name;
  • profile picture/avatar;
  • telephone number /contact number;
  • IP address;
  • address;
  • local time, calculated based on the address;
  • other photographs.

2.5. In the case where a Family Bond or a Family Member is a natural person below 14 years old, the data about him/her will be processed on the ground of a written and voluntary express written consent of the legal representative of the person who exercises the parental control and bears responsibility for him/her. The purpose of the collection of these data is to provide adequate and personalized service which takes in consideration the age factor.

2.6. For the purposes of the Application and in view of its lawful operation, the capacities of a Family Admin and an Assistant can be occupied only by persons who are of age and legal capacity according to the Bulgarian legislation.

Please, contact us, if you think that we have wrongly or unconsciously collected information from a person aged below 18 years.

2.7. Information that is collected automatically when the User uses the Application:

2.7.1. Information on the visits and activity in the web module of the Application, including the content viewed and used by the User. Part of this information is collected by means of instruments for automatic data collection, including cookies and web marks. 

2.7.2. Anonymous answers to survey questions or summarized information on how the services of Circle4Care are used. In the course of its work, Circle4Care applies a de-identification process or pseudonymization of the data, so as to bring to a minimum the probability that the user will be identified using these data with existing technologies.

2.8. Information from third parties

2.8.1. Circle4Care receives information from third parties which is deemed to be reliable and is available to the public. This information is personal data such as: name, address, email address, interests and certain demographic data.

2.8.2. In order to provide certain services at the corporate level, Circle4Care receives your company’s contact details from a specific employee of your organization. When necessary, Circle4Care can use this information provided by you or your employer, together with online information which is available to the public and other online and offline sources, in order to contact you concerning the service provided.

2.9. The Company, as a personal data Administrator, performs the following operations and processes only the necessary personal data, for the following purposes:

2.9.1. for registration of Users in the platform, to install and use the Application and its functionalities;

2.9.2. to issue invoices and/or other documents related to providing subscription access to the platform;

2.9.3. for direct marketing;

2.9.4. for statistical purposes.

2.10. Each user of the mobile application will install it on his/her device (smartphone or tablet) and use it voluntarily, entering data completely voluntarily. The ground for the processing of your personal data by us for the above-specified purposes is your consent. Your express consent is also the ground for processing the special category data which we process, namely, information about your state of health. Even if we don’t see this information, since it is accessible only for you and the participants in the given Family Circle, we process it in an encrypted state through the Application, so that it can operate and fulfill its purpose.

2.11. Circle4Care will issue an invoice or another accounting document for the subscription fee paid by the Natural Person – Family Admin, based on the name and surname entered by the Family Admin. The processing of the PIN will take place only after the person has made an express request to issue an invoice with this requirement.

2.12. For statistical purposes, Circle4Care has the right to use the data, respectively, part of them, for its own purposes, such as: internal analyses; to prepare recommendations, conclusions concerning improving the content of Circle4Care or the manner of work; build summarized data for each user’s use of Circle4Care and other.

2.13. Circle4Care can process the personal information also in connection with the development of new and the improvement of existing products, making users aware of legal and regulatory requirements, providing or sending to the User improvements and updates or notifications for improvements and updates of the Software or other products and/or services by Circle4Care.

2.14. Part of the abovementioned personal data of natural persons, namely Name and Email address, are processed for the purposes of direct marketing conducted by Circle4Care. Direct marketing is conducted only to persons who have not objected to it. When a natural person is an object of direct marketing on the part of Circle4Care, he/she has the right to object against it, as a result of which he/she will no longer receive marketing messages, until the moment when he/she requests it. Objecting against the conducted direct marketing by email is done by clicking on a link to refuse receipt of advertising messages. The link is always in a visible place and its purpose is understandable.

  1. Data Protection

3.1. Reasonable technical and administrative measures have been implemented at Circle4Care to protect the personal data which are processed, in order to ensure that unauthorized persons will not have access to them and that they won’t leak, as well as to guarantee their correct use according to the law and for a period during which these data are legitimately necessary to us.

  1. Data Sharing

4.1. Circle4Care will share the Users’ personal data in the following cases:

4.1.1. Sharing with service providers

Circle4Care may use service providers to perform certain activities on behalf of Circle4Care. These service providers may be located both in European Union and European Economic Area countries and in the USA or other countries around the world and offer services, such as credit card payment processing, client support, personalization and content, IT services, email service providers, data hosting. The providers of services to Circle4Care are obliged, by virtue of the legal relationship arisen and the legal regulations, to protect the personal data received from Circle4Care and are not entitled to use them for any other purposes, except to provide the services according to Circle4Care’s instructions.

4.1.2. Corporate reorganizations

If at any given time Circle4Care restructures its activity by reorganizing the trading company, as a result of the reorganization personal data may be transferred to a possible legal successor and Circle4Care will be obliged to provide adequate protection for the Users’ personal data in this type of reorganization.

4.1.3. Compliance with the law

Circle4Care may share the Users’ personal data, if it is obliged to: (a) answer duly authorized requests for information by law enforcement authorities as well as to comply with the requirements for national security and other requirements of law-enforcement authorities; (b) comply with a law, ordinance, subpoena or court order; (c) investigate and assist in the prevention of security threats, fraud or other criminal or malevolent activity; or (d) protect the rights or the personal safety of its employees and third parties, according to the legislation in force.

4.2. With the goal to facilitate the registration in the mobile application, in certain cases it is possible to extract the data from the given natural person’s profile in any of the social networks (for example, Facebook, LinkedIn, etc.) and this could happen only and solely when this person has expressly stated that he/she wishes such data transfer to occur. 

4.3. Like most websites, the mobile application Circle4Care collects data in log files. This information contains the user’s IP address, as well as which browser is used (such as Mozzilla, IE, Chrome and other), the operating system (Linux, Windows, iOS), when he/she visits the mobile application. Circle4Care reserves the right to use the users’ IP addresses to find their identity in the cases where this is necessary to comply with the law.

4.4. Circle4Care is entitled to provide personal data of the User to third parties with the purpose to offer quality, fast and integrated service. The personal data are provided after Circle4Care has stated that all technical and organizational measures have been taken to protect these data.

  1. Recipients and Categories of Recipients

5.1. In connection with the fulfillment of the above-specified purposes, Circle4Care provides the personal data of the natural persons to the following recipients:

5.1.1. the National Revenue Agency – in the event of inspections and audits;

5.1.2. other state and municipal bodies and/or institutions – in connection with legal obligations towards them or in connection with legal requirements by them for information containing personal data;

5.1.3. subcontractors fulfilling contractual obligations.

  1. Cookies

6.1. To make user visits of the mobile application Circle4Care as functional as possible, we use the so-called “cookies”. The cookies represent small text files (computer data) which are saved on the computer (mobile device) of the respective user and are meant for use by websites. These data allow to identify the user’s device and the correct functioning of a given website, according to his/her preferences. Cookies usually contain the name of the website, the storage time in the end device and a unique number.

6.2. Circle4Care uses the following cookies to improve the use of the Application:

6.2.1. cookies which are necessary for the operation of the user search which allow using the main functionalities of the mobile application and maintain possible the identification of the User the entire time;

6.2.2. personalizing cookies which allow the User to visit the Internet pages in a personalized manner, according to his/her previous visits and searches. These cookies allow the Users to find the result sought by them faster.

6.3. Through the respective browser setting, each User can turn off some or all cookies. In this case, you may lose part of the functionality of the platform, including some of the services.

6.4. In the event that the user uses a link transferring him/her to another site, that site will have its own cookies and security policy which are beyond the control of Circle4Care.

  1. Information to Contact Circle4Care

7.1. The users of the mobile application can ask their questions concerning their personal data processing or exercise some of their rights by contacting the platform’s team using the following contact information:

  • name: Zhenya Atanasova  – personal data protection officer;
  • email: [email protected];
  • address: city of Veliko Tarnovo, 57 Vastanicheska Street, fl. 1.
  1. Principles of Personal Data Processing

8.1. Compliance with the provisions of the Regulation

Circle4Care’s policy seeks to provide compliance with the provisions of Regulation 2016/679 and the Law on personal data protection.

8.2. The personal data are collected and processed according to the law and in good faith

Circle4Care collects and processes personal data according to the law, in good faith and in line with the principles and rights of natural persons related to the processing of their personal data.

8.3. The personal data are collected and processed for specific purposes only

Circle4Care will process the personal data of natural person only in the following cases:

8.3.1. for the purpose to comply with our obligations towards Users when they use the product developed by Circle4Care;

8.3.2. for the purpose to carry out Circle4Care’s activity effectively, implement innovations and for a seamless user experience;

8.3.4. when a natural person has provided his/her unambiguous consent for a clear and transparently defined purpose of Circle4Care for which it is necessary to process his/her personal data;

8.3.5. when the processing is necessary to fulfill a legal obligation of Circle4Care;

8.3.6. when the processing is necessary to fulfil a contract with Circle4Care, under which a natural person is a party or to take action under a request by a natural person before concluding a contract when his/her identification is necessary;

8.3.7. when the processing is necessary to protect vital interests of the natural person whose personal data are processed or of another natural person;

8.3.8. when the processing is necessary for the purposes of Circle4Care’s or a third party’s legitimate interests, according to the provisions of the Regulation;

8.3.9. when the processing is necessary for the purposes of analysis and business intelligence, development of new products, improvement of systems and indicators on the ground of Circle4Care’s legitimate interest, namely, continuously improve and develop its products.

8.3.10. for another lawful purpose or in the other cases provided in the Regulation.

8.4. Personal data which are not necessary for the activity will not be collected and processed

Circle4Care will not collect nor process personal data of natural persons which exceed its obligations according to the law or its needs for making business. 

8.5. Limitation of purposes

Circle4Care will use the User’s personal data only for the purposes specified as of the moment of their collection, as well as for additional purposes compatible with them, according to the law.

In all cases, when it is necessary collected and processed personal data of natural persons to be used for purposes different from the initial ones, Circle4Care will inform the respective natural person, request their consent and will proceed with the processing of their personal data for other purposes only after his/her express consent. 

8.6. The personal data will be processed transparently

Circle4Care will provide transparency in the communication on the collected and processed personal data and this information will be in a short, transparent, intelligible and easily accessible form and clear and unambiguous language will be used. The User him/herself will decide whether and how to use the Application and its functionalities. The registration forms which the User will fill in have fields marked as obligatory without which it will be impossible for Circle4Care to provide access to the main functionalities of the Application.

8.7. Right to informed choice

Circle4Care will always provide Users with precise information and will give them the right to choose about the type of personal data it collects from them, as well as about the purposes and duration for which it collects and processes them. Circle4Care will not use Users’ personal data for purposes incompatible with these principles, with the Personal Data Protection Policy or with specific notifications related to the services provided.

8.8. The minimum necessary personal data will be collected for processing

Circle4Care will collect and process only the minimum necessary personal data of natural persons which:

8.8.1. are provided in the law;

8.8.2. are necessary to fulfill a contract;

8.8.3. are necessary to fulfill the purposes for which they are collected;

8.8.4. were provided by you voluntarily and after your consent.

8.9. The processed personal data are exact and up to date

Circle4Care ensures that the processing of the personal data of natural persons is performed with maximum precision and possibly always up to date.

8.10. The personal data are processed by the minimum necessary number of persons

Circle4Care ensures that the access to and processing of the personal data of natural persons are performed by the minimum necessary number of persons (operators) who have the necessary competence for their processing and the necessary commitment to their protection.

8.11. The personal data will be stored for the minimum necessary duration

Circle4Care will store personal data for the minimum necessary duration:

8.10.1. required by law;

8.10.2. required to fulfill a contract (including and order) and the liability under it;

8.10.3. necessary to fulfill the purpose for which the data was collected and processed;

8.10.4. until a natural person requests to delete them, after which they will be deleted without unnecessary delay;

8.10.5. until expiry of the period for which Circle4Care has the right to store the data based on legitimate interest.

8.12. In all cases, Circle4Care provides at least once a year a review of the personal data collected and processed and those which appear in one of the above scenarios are deleted without undue delay.

8.13. Circle4Care will keep the information and the personal data of the users of each Circle for 30 days after expiry of the respective subscription and, in the absence of a subsequent subscription payment, will delete them automatically.

  1. Rules for Personal Data Processing

9.1. The personal data are processed with the necessary protection levels and measures

Circle4Care provides the necessary levels of physical, organizational and technological protection, in view of:

9.1.1. the nature, scope, context and purpose of the personal data processed;

9.1.2. the probability, impact level and severity of the risk for the rights and freedoms of natural persons in the case of violation of the security of the personal data processed;

9.1.3. its financial and organizational capabilities.

Circle4Care also provides all necessary levels for the prompt restoration of collected and processed personal data in the event of their loss as a result of accident, ill intentions or force majeure events.

9.2. The personal data are processed with controlled and traceable access

Circle4Care provides the necessary and suitable technical, organizational and technological measures for controlled and traceable access to the personal data of natural persons, as well as the possibility to review, correct, supplement, transfer or delete the user personal data shared with us. 

9.3. Personal data are processed with the necessary accountability to comply with the Regulation

Circle4Care provides the necessary accountability and registries in order to be able to prove compliance with the provisions of the Regulation. 

9.4. Data security

In order to protect user personal data from misuse, Circle4Care applies strict measures to protect the stored information and requires the same level of security from its partners to whom it provides it, in order to fulfill the obligations assumed with respect to the Users.

9.5. Respect for the rights of the natural persons whose personal data are processed

Users have the right to access all personal data provided by them or about them stored by Circle4Care. They are also entitled to request correction, supplementation, restriction, transfer or deletion of their personal data, as well as to request clarifications in relation to their processing. In certain cases, the User’s requirement may be rejected on the ground of a law, for example, when providing the information will disclose the personal data of another person or when there is a prohibition by law to disclose such information.

9.6. Circle4Care ensures the compliance with the rights of natural persons whose personal data are collected and processed, which includes:

9.6.1. right to be informed about personal data processing;

9.6.2. right of access.

The User may request from Circle4Care a confirmation of whether it processes his/her personal data and, if the answer is yes, request access to them. This happens after the User sends a request to Circle4Care, at the address specified below.

9.6.3. Right to correct inaccurate data

You can request from Circle4Care to correct your inaccurate personal data or to supplement those which it already has.

9.6.4. Right of objection

If Circle4Care is processing your personal data on the ground of its legitimate interest, you have the right to object at any time with respect to the processing of these personal data for this specific purpose.

9.6.5. Right of deletion (right to be forgotten)

Under specific circumstances, it is possible to request from Circle4Care to delete your personal data and, if the law allows it, Circle4Care will do this as soon as possible. In such case, Circle4Care will no longer be able to provide its services to you.

9.6.6. Right to restrict the processing

You can request from Circle4Care to restrict the processing of your personal data. In this case, the respective data will be marked and they will be processed by Circle4Care only for specific purposes.

9.6.7. The right to be informed about actions as a result of a request for correction, deletion or restriction of the processing of personal data

9.6.8. Right to data portability

Under specific circumstances, you may have the right to receive your personal data which you have provided to Circle4Care in a structured and frequently used format which is machine-readable (for example, in digital format) and request their transfer to another person, without Circle4Care hindering that, if such transfer is technically possible.

9.6.9. Right to object against the personal data processing

9.6.10. Right to file a complaint before a supervisory body.

9.7. If you think that your rights in relation to personal data have been violated, please contact Circle4Care, in order for it to try to find a solution to the problem.

9.8. You can also contact the local personal data protection authorities and file a complaint with them, specifically if you live in a European Union country, at your permanent residence or at the place of the alleged violation.

9.9. In Bulgaria, this is the Commission for Personal Data protection, information about which you will find below.

9.10. You can send a request to exercise the rights described above to the following email address: [email protected]

9.11. Contact us

We at Circle4Care value your opinion. If you have any questions or worries about our Policy on Personal Data Protection, the collection and use of your personal data or in relation to a possible violation of the law on personal data protection, you can contact us using the above contact information of Circle4Care.

  1. Competent Supervisory Body

The Commission for the Protection of Personal Data (CPPD) is the independent state body which implements the protection of individuals in the processing of their personal data or the realization of the access of this data, as well as the control on the fulfillment of the Law on Personal Data Protection on the territory of the Republic of Bulgaria.

In the event of any doubt that rights established by law have been violated which are related to personal data protection, every User can send an alert to CPPD at:

  1. Changes In The Privacy Policy

Circle4Care reserves its right, at any time, without advance notice and without your prior and express consent, to modify the present Privacy Policy, while strictly complying with the provisions of the General Data Protection Regulation 2016/679. Circle4Care will inform you about any change upon each subsequent access to the platform. 2082751Circle4Care