Privacy policy

This Personal Data Protection Policy is valid as from  01.11.2022.‍

1. Introduction

This Privacy policy („thePolicy“) governs  the relations betweenYou, the website Users, on one hand, and "HRS Recruitment Services" EOOD, entered inthe Commercial Register to the  RegistryAgency under EIC: 205038277, seated in the city of Sofia, 11 – 13, Yunak St., 2ndfloor, registered at the National Employment Agency to the Minister of Labourand Social Policy No 2525/ 26.04.2018, EIC: 205038277, represented by GeorgiHristov Angelov and Kiril Ivov Boradjiev – General Managers („HRS“ and/ or theController and/ or We), in our capacity of Administrator of the Website https://www.hrs-bg.com.

HRS pays great attention to thepersonal data protection, and we collect and process personal data only incompliance with the requirements of the national and the EU legislation . The purpose of this “Privacy Policy” is to inform You on how we process Your data and what types of personal data we would collect aboutYou, for what purposes, terms, and respectively what are Your rights.

This Policy  is fully compliant with the General Data Protection Regulation (EU) 2016/679 and any other applicable legislation,related to personal data protection. Any change of the Policy  will be duly updated on the Website, whereasthe date of validity at the beginning of the document will be changes and theusers will be notified to the e-mail addresses, provided by them. If  You disagree with any part of our Policy, please do not  generate any registration in the Website anddo not  use our services. If you continueto use the Website after the amendments, we will consider these actions as your acknowledgement of and agreement to our Privacy Policy.

2. Definitions

For the purpose of this Statement the definitionsbelow will have the following meaning:
  • „Personal Data Controller“ means a  natural person or a legal entity  who will determine the personal dataprocessing purpose and tools independentlyor together with other persons;
  • „Company“ is the Administrator of theplatform "HRS Recruitment Services" EOOD; 
  • „Personal Data“ means any information, related to an identifiednatural person or a natural person, that could be identified(„You“, „You“, „Data Subject“or „User/s“);
  • „Processing“ means any operation or set of operations which isperformed on Personal Data or on sets of Personal Data;
  • „Personal Data Processor” means any natural person or legal entity , publicauthority, agency or any other structure that is processing Personal Data onbehalf of the Controller;
  • „Recipient“ meansany natural person or legal entity , public authority, agency or any otherstructure, to which the personal dataare disclosed, whether a third party or not;
  • „Personal data breach“ means a breach of security leading to the accidentalor unlawful destruction, loss, alteration, unauthorized disclosure of, oraccess to, Personal Data transmitted, stored or otherwise processed.
Any other definitions that are not  explicitly shown here, shall be used in the irrespective meaning, shown in the General Terms of Use, applicable to the Website.

3. Personal Data Controller

TheCompany shall process the Personal Data of the Website Users in the capacity ofan independent Controller. The employers should be considered as independentPersonal Data Controller, who receive Personal Dataabout the Job applicants.

TheController shall collect and process Personal Data of the following categoriesof persons, namely: Job applicants, who applied with us; Applicants, who weprovide or to whom we provide a job with some of our customers /employers/;Website Users https://www.hrs-bg.com/en/submit-cv, as well as persons who apply through the platformsof our partners: jobs.bg, zaplata.bg, rabota.bg, etc.; It is possible thatPersonal Data of users  is collected andprocessed (e. g. video surveillance data).

4. What Personal Data do we collect?

Depending on the services that You  use we may collect and process the followinginformation:
  • Full name;
  • Date of birth;
  • Email;
  • Password;
  • Contact phone number;
  • User name;
  • Data on the education graduated and any additionalqualifications, incl. language proficiency;
  • Data on prior experience and employers;
  • Data from work permits;
  • Letters and digital messages that we receive fromYou in the communication between us;
  • Video cameras footage for protection and security,when You visit our administrative facilities;
  • Other data, collected when You use a contact form.


In the course of use of our website we may collectand process:
  • user name and password;
  • digital address, data regarding the activity in theprofile;
  • other information,voluntarily shared by You.

We do not  collect any sensitive Personal Datasuch information about race, religion, sexuality and/ or religious beliefs. Even if we receive such information, we will not processit.

5. Purposeof the processing Your Persona Data

HRS willprocesses Your Personal Data only for the purposes, for which it was collected,and for no other purpose. Those purposes are exclusively related to our coreactivities – recruitment, consulting, analysis and career support. The purposescomply with the legal requirements pursuant to the Ordinance on the terms andprocedure for conducting job placement activities, etc.

Those purposes are in particular:
  • Concluding contracts with HRS;
  • Contract administration;
  • Accessto our data base by employers;
  • Financial relations;
  • Application and request processing;
  • Matching applicants with employers;
  • Sending vacant position alerts;
  • Managing, evaluating and improving our business;
  • Management,assessment and improvement of our activity; 
  • Providing additional services like trainings, career consulting and career development;
  • Valuationof the job applicants’ employability;
  • Providing efficient communication;

6. Legal basis

In the greatest number of cases, we request Your personal data and weprocess it (alternatively) based on the execution and performance of acontract, in order to comply with the legal requirements or to protect ourlegitimate interest. Clearly, for some of the services You provide suchinformation to us by yourself, whereas You elect and agree for it to beprocessed. Without such data, we would not  be able to provide the respective services.

 

The legal basis for processing is also related toour core activities – recruitment and career consulting and to our license fromthe National Employment Agency that allows us to conclude with the applicantsJob Placement Contracts that we must register in the information platform ofthe Agency.
 
  • Processing of the data, necessary for the conclusion and the performance of contracts in order to execute obligations from concluded contracts for providing training services; Providing comprehensive services and administration;
  • Processing of the data that we need in order to comply with legal obligation pursuant to the Ordinance on the terms and procedure for conducting job placement activities and other related legal instruments. Obligations to provide information to all public commissions and regulatory bodies; providing information to the court and the law enforcement bodies.
  • Processing of data based on Your consent – data transfer beyond the EU borders; direct marketing.
  • Processing of data in order to protect our legitimate interest –video surveillance in our administrative facilities;
  • Disclosure of Your information:
HRS involves thirdparties in order to support some of its contractual activities or to complywith some statutory obligation. We do not  disclose any of Your Personal Data to third parties, until we have that all technical and organizational measures have been taken in order to protect this Personal Data, and we aim to keep strict controlin order to reach this goal. We may supply data to accounting offices, to theIT companies that maintain our Website, etc.

In some cases, the disclosure of Personal Data is mandatory in order to comply with our legal requirements and in this regard, we deliver informationto: the National Employment Agency; the National Revenue Agency; the Ministry of Interior and to other regulatory and investigation bodies upon request and for inspection;
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7. Automated algorithms

We donot  use any automated decision-making tools.

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8. What methods of Personal Data collection do we apply?

HRS collect Personal Data from various sources – when you apply in our offices in person, through our Website, from public information platforms for job seekers (e. g.: jobs.bg, zaplata.bg, rabota.bg, etc.), through social network channels (e. g. Facebook and LinkedIn, etc.), at events, via telephone or e-mail, from job applications and in connection with personal recruitment in the course of our relations with clients and suppliers. 

The listed Personal Data is collected and processed only for the purposes that it was initially collected for. If we change the purpose or the way of processing, we will contact you with additional information about the legal basis, the purpose and the tools for processing Your personal data.

 

9. Data storage

HRS may transfer Your personal data beyond the EU borders to potential employers, but only with Your explicit written consent or in the conditions of derogation and compliance with a contract.

The safety of the data that You entrusted to us is very important for us. That is why we are protecting your data by applying all appropriate technical and organizational means at our disposal , in order to prevent unauthorized access, unauthorized or malicious use, loss, or premature  deletion of information.

HRS applies measures for the protection of your personal data from accidental loss unauthorized access, use, modification or publishing. Policies and procedures are applied, intended to protect the information from loss, abuse and unauthorized disclosure. We are taking also further measures for information security, including access control, strong physical protection and reliable practices for the collection, storage and processing of the information. These actions include among others:


1. Physical organizational and technical protection measures: designation of controlled access areas; designation of the premises, where personal data is processed, incl. those where our servers are located, and restricted access; determining the organization of physical access; designation of the technical means used for physical access – in special rooms and locked cabinets; setting up of a team for response in case of violations.

2. Personal protection: instruction of the staff about the specifics of personal data processing and about the legal framework in the field of personal data protection, about this policy and other relevant internal regulations; confidentiality of information; personnel training.

3. Document protection: definition of the of the storage periods; dissemination rules, procedures for destruction, processing monitoring and control. Furthermore, we apply technical measures such as encrypting, pseudonymization and anonymization of the Personal Data collected.

10. When do we delete your Personal Data?

When the storage period has expired, we launch deletion of all Personal Data and copies available, unless the EU legislation  or the legislation of the Republic of Bulgaria regarding the Personal Data protection require that the data remains kept as legal obligations, legal requirements, public investigations, investigations of possible violations of our terms and rules or aiming at preventing damages to the Controller.

 

Some storage periods are:

- 5 years – for applicant data pursuant to Art. 41, par. 2 of the Ordinance on the terms and procedure for conducting job placement activities

- 3 years – for own recruitment as employer, pursuant to the Personal Data Protection Act;

- 10 years pursuant to the Accountancy Act for storage and processing of accounting data;

- 30 days from the recording for video surveillance data;

11. What are your rights and how can you exercise them? 

You have the legal right to: 
  • To unsubscribe from receiving commercial messages;
  • To have access to the personal information that we store for you, in a convenient digital form;
  • To edit, add, delete and manage the information in Your profile at any time;
  • To require correction of the collected Personal Data, if they are incorrect;
  • To receive a copy of your Personal Data in a digital form;
  • You are entitled to require deletion of your Personal Data – i.e.. „the right to be forgotten“, however, this right is not absolute (exceptions – the available Personal Data is necessary for exercising the right of free speech; there is a legal obligation to store this data; from reasons of public interest);
  • To receive from us information about our actions with regard to Your Personal Data, inclusive the purpose of collection and storage, storage period, collection method, etc.;
  • To receive Your data and to transfer them to another Personal Data Controller;
  • To contact us in case of questions, complaints or other problems, occurred with the processing of Your Personal Data;
  • You may submit a complaint to a supervisory body, in particular in the member country of your permanent residence, employment or the location of the presumable violation, if you consider that there is Personal Data breach.


The applications for information access or correction are submitted by You in person or by a specially authorized person with a special written Power of Attorney. You can submit the application also digitally by order of the Electronic Document and Electronic Signature Act.

In case of questions or claiming right with regard to the Personal Data Protection you can contact the HRS staff as follows:

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Email: dataprotection@hrs-bg.com

Phone: 02 419 1414

We will reply to all requests, related to the privacy, in the due time and within the legally defined terms. In case of any unsolved problem with the privacy of your Personal Data processing you can contact the local Personal Data protection body.

12. How and to whom is Your Personal Data shared to?

Every independent Controller must guarantee the safety of the Personal Data, processed by them.

12.1. With other platform users

When you register, a Profile is generated, whose  information can be accessed by employers, whouse the Website. The employers see the following information: names, CV,picture and every other information mentioned in the CV.

12.2. Information that is shared in order to protect our services and tocomply with the legislation

We reserve the right to disclose Your information,when we have conscientious reasons to believe that the law requires it from us,when it is necessary for the prevention and the solution of frauds,unauthorized use of our services, violation of our General Terms of Use orother detrimental illegal actions, as well as in order to protect our Users.

In this regard it is possible that Your Personal Datais shared with third parties – recipients under the following circumstancees
  • aiming at compliance with a legal requirement, a court procedure, a court order or a court procedure with regard to a Controller or its branches, subsidiaries, associates;
  • aiming at an investigation of a possible crime like an identity theft;
  • with public authorities in compliance with their legal obligation to implement their official mission like tax and customs bodies, financial investigation units, independent administrative bodies, etc.;
  • with regard to a transformation (fusion, merger, separation and splitting), sale, purchase, business transformation, termination, liquidation, insolvency of the Controller;
  • when we consider that it is necessary to protect the rights, the property or the safety of the Controller or other persons, related to him; or
  • when the law requires or allows otherwise, inclusive all contractual obligations of the Controller.

13. Personal Data Protection Policy

This procedure of Personal Data protection may be changed from time to time. Such changes will take effect immediately after being promulgated. Regularly reviewing this page ensures that you will always be aware of what information we collect, how and for what purposes HRS uses it, and under what circumstances (if any) we will share it with other parties.

 

14. Supervisory body

The local Supervisory body on the territory of the Republic of Bulgaria in matters, regarding Personal Data, is:

Commission for Personal Data Protection, Address: Sofia, 1592, No 2, Tsvetan Lazarov Blvd., Phone: +359 2 915 3580, Fax: +359 2 915 3525, e-mail: kzld@cpdp.bg, website: http://www.cpdp.bg/.



Do not  hesitate to contact us per e-mail dataprotection@hrs-bg.com in case of any questions about this Statement.