GENERAL POLICY FOR THE PROTECTION OF PERSONAL DATA OF "EASY CONSULT" LTD
Applicable from: May 2018
This General Policy explains how we collect and process your data in our capacity as Administrator.
YOUR RESPONSIBILITIES:
We, "EASY CONSULT" LTD, are the Administrator regarding your personal data and are responsible for them. Our main activity is in the field of EMPLOYMENT. As this activity is specific, we have developed separate policies for it, published further down on this page under the headings "Privacy Policy - Recruitment and Recruitment" and "Privacy Policy of workers/employees in temporary work'.
Familiarize yourself with them accordingly if you use our employment services.
If you have any questions about any of our Policies or about your personal data, please contact us.
Contact details with us:
"EASY CONSULT" LTD, EIC: 115829812, registered office and management address: city of Sofia, district "Mladost", g.k. "Mladost 4", Business Park Sofia, Building 15, ground floor,
You can contact us at the above address as well as at e-mail: dpo@easyconsult.eu,
We have appointed a Personal Data Protection Officer. Contact details: dpo@easyconsult.eu.
It is very important that the information we have about you is correct and up-to-date. Please inform us of any changes or if you notice any errors.
We process personal data for specific purposes and on relevant legal grounds, depending on your role with us.
3.1 When you are a visitor or user of our website www.easyconsult.eu
A) Automatically collected information: You may access the website without entering personal data. But even in this case, certain information is automatically processed, such as log files /event files/, cookies, and analysis of the website through Google Analytics.
B) Social plugins or buttons /Social Plug-in/ Facebook, Twitter, Linkedin or others. Their use is at your discretion. These buttons represent a link to third-party sites that, using cookies, collect and process personal data according to their own policies. We are not responsible for them, but in view of your awareness and rights, we ask you to familiarize yourself with them.
We have placed these plugins to make our website more functional for visitors, and to promote our business and services if you voluntarily share our content on the relevant sites. We accept this as our legitimate interest.
B.1. Information about social plug-ins used
Link about Google Analytics.
In order to continuously improve our website, we use Google Analytics, a web analytics service of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies", which are stored on your computer and enable an analysis of the use of the website. The information generated by the cookies about your use of this website is usually sent to a Google server in Europe (or in a member state of the European Economic Area) to anonymize the IP address so that all personal characteristics are excluded. Only after it has been anonymized is the abbreviated IP address transferred to a Google server in the USA and stored there. Only in exceptional cases is it necessary to transfer and store the full IP address on a Google server in the USA. This website uses Google Analytics with an extension for the anonymous collection of IP addresses (so-called IP masking). On our behalf, Google will use the collected information to evaluate the use of the website, compile reports on website activity and provide other services related to the use of the website. The IP address transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser. We would like to point out, however, that in this case, you may not be able to fully use all the functions of the website. You can also refuse Google to collect the data generated by cookies related to the use of the website (including your IP address) and process this data by downloading and installing the browser plug-in available from the following link: compiling reports on website activity and providing other services related to the use of the website. The IP address transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser. We would like to point out, however, that in this case, you may not be able to fully use all the functions of the website. You can also refuse Google to collect the data generated by cookies related to the use of the website (including your IP address) and process this data by downloading and installing the browser plug-in available from the following link: compiling reports on website activity and providing other services related to the use of the website. The IP address transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser. We would like to point out, however, that in this case, you may not be able to fully use all the functions of the website. You can also refuse Google to collect the data generated by cookies related to the use of the website (including your IP address) and process this data by downloading and installing the browser plug-in available from the following link: transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser. We would like to point out, however, that in this case, you may not be able to fully use all the functions of the website.
You can also refuse Google to collect the data generated by cookies related to the use of the website (including your IP address) and process this data by downloading and installing the browser plug-in available from the following link: transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser. We would like to point out, however, that in this case, you may not be able to fully use all the functions of the website. You can also refuse Google to collect the data generated by cookies related to the use of the website (including your IP address) and process this data by downloading and installing the browser plug-in available from the following link: https://tools.google.com/dlpage/gaoptout?hl=en An opt-out cookie is created to prevent your data from being collected when you visit this website in the future. Additional information on data protection in Google Analytics can be found at https://www.google.com/analytics/terms/bg.html and at https://support.google.com/analytics/answer/6004245?hl= en.
Link about social plugins
Facebook Social Plug-in: We have included a button on the social network Facebook (1601 South California Avenue, Palo Alto, CA 94304, USA - www.facebook.com ) on our website. You can recognize the Facebook buttons by the Facebook logo or the "Like" button.
As a website operator, we have no information about the content of the transmitted data or its use by Facebook. We also do not know when you clicked on any button. For more information about how Facebook uses your information, please see Facebook's Privacy Policy https://www.facebook.com/policy.php#
Social Plug-in/ Instagram. We have included an Instagram button on our website. We have no information about the content of the transmitted data or its use by Instagram. We also don't know when you clicked on any button. For more information on how Instagram uses your information, please see their terms at https://help.instagram.com/519522125107875
Twitter Button: Our website uses Twitter service buttons. These buttons are provided by Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. They are identified by terms such as "Twitter" or "Following", presented together with a stylized blue bird. Using the buttons, it is possible to share a post or offer from this website on Twitter or to follow the provider on Twitter. When you access an area of the website that contains such a button, your browser establishes a direct connection to Twitter's servers. The content of the Twitter button is transmitted directly from Twitter to your browser. For this reason, we have no influence on the amount of data that Twitter collects with the help of these plugins, and we only inform you based on the information we have. http://twitter.com/privacy.
LinkedIn Conversion Tracking: On our website, we use the analytics and conversion tracking technology of LinkedIn Corporation (2029 Stierlin Court, Mountain View, CA 94043, USA - www.linkedin.com - " LinkedIn"). With this technology, LinkedIn can show you ads based on your interests. In this way, we also receive aggregated and anonymous reports from LinkedIn about advertising activity and information about how you use our website. Further information on LinkedIn's data protection can be found here: https://www.linkedin.com/legal/privacy-policy#choices-oblig. You can object to LinkedIn's analysis of your behavior and the display of recommendations based on your interests by clicking "Opt Out of LinkedIn" (for LinkedIn users) or "Opt Out" (for other users) by following the following link: HTTPS: //www.linkedin.com/psettings/guest-controls/retargeting-opt-out
C) Links to other sites.
Our site may link to other sites. If you choose to follow these links, please read the privacy policies of the respective sites in detail to understand how your information will be processed by third parties.
D) Personal data that you provide to us through the website.
When you use our contact form or another of our services on the website, we process personal data for the purpose for which you provide it to us, i.e. according to the specific function and your request. It is in our legitimate interest to respond to your request. The mandatory fields that we have set (for example, in the contact form) are the minimum information that we have determined that we need. Please do not provide us with personal information about you that is not necessary for the relevant purpose. We also process the information that is created in view of our interaction, for example, the content itself of messages through the website.
Sometimes we process your data on a so-called pre-contractual basis. We apply this basis in all cases in which you request to conclude a contract with us and we process your necessary data for this purpose. In other cases, there may be a concluded contract between us, and the processing of your personal data through the website is in connection with the fulfillment of our contractual obligation. If you are applying for a job with us (ie as an employee of ours, outside of our temporary employment services), please read item 3.9. below.
E) Sensitive data about you /special categories of data/.
We do not collect such data about you. Special categories of data, or "sensitive data", are those revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the sole purpose of identifying an individual, health data condition, sex life or sexual orientation. Please do not provide us with such data. Providing such data, as well as other personal data that is not necessary for the relevant purpose of our interaction with you, exposes your rights to unnecessary risk.
F) Combining information.
Sometimes we combine information collected through the website with other information that we receive from you through various communication channels /for example, by email, phone/ or from other sources - public sources, such as the Commercial Register, or from third parties - rating companies, professional profiles, our partners with whom you also interact in connection with your relationship with us, for example when you have requested a service the provision of which is linked to a third party. When we combine this information, we do not use it for a different purpose of which we have not informed you.
3.2. If you are a visitor to our office:
In this case, we will ask you to introduce yourself and provide us with basic information about you /your names, organization you work for or represent/, we can also reflect the day you visited us, sometimes the specific time for this, as and information about the individuals you have met. We will use this information in view of our legitimate interest in controlling access to our office and security, and to report and monitor internally the activities of our employees with whom you meet.
3.3. If you are a participant in our event (conference, presentation, cocktail party, charity event and others):
We will collect the necessary information for your inclusion and participation. Sometimes we may ask for information about your preferences to make the event more enjoyable or useful for you. In some cases, events may be captured by cameras or cameras, and we may use relevant recordings or photographs, as well as information about your participation, to promote our event in the media, on our website, in a presentation or otherwise. If this bothers you, you can inform us in advance that you do not want us to publish information about you or your image.
We will also retain basic information about you to contact you from time to time and to send you information about other similar events of ours. We may also ask you for feedback on how you rate our event. You always have the right to object to this way of using your data, as described below in relation to your rights.
3.4. If you are a participant in our promotional campaign.
Sometimes we organize such campaigns, for example through our social network profiles. In these cases, we will process the information you provide to us for the purpose of your participation in the relevant campaign.
3.5. If you "follow" us on social networks.
If you have "liked" our profile on a social network or "followed" it, according to the practices of the respective networks, you will see messages, advertisements or materials published by us on our page. If you make an inquiry to us through the relevant page or, for example, comment on our publication, we may use the functionalities of the same network to respond to you, and if you have requested that we contact you in another way / for example, by giving us your telephone number/, we will comply with your request in view of our legitimate interest in responding to your inquiry, for example.
3.6. If you are a participant in our training:
We will collect the necessary information to register you. We will process the information about your participation, presentation, exam /if such is held/.
We will also keep basic information about you in order to contact you from time to time and send you information about other such trainings of ours. We may also ask you for feedback on how you rate our training. You always have the right to object to this way of using your data, as described below in relation to your rights.
3.7. If you are our business contact:
This means that you represent an organization - our partner, customer or supplier or are an employee of it. In order to maintain our business relationship with the organization, we will often need information about you, for example: Your names, telephone, email, skype contact, business card, information about your position in the relevant organization. We will also process the following information: written/electronic or other correspondence with you; data contained in documentation relating to our relationship with the organization, for example your signatures, description of your conduct, your statements, etc.; any other information we need in connection with the business relationship with the organization.
3.8. If you are our potential business contact:
This means that you represent an organization - our potential partner, customer or supplier, or are an employee of it. We may have your information from a professional public register, from a common business contact of ours who referred you, you gave us your business card or contacts at an event or meeting. In these cases, we will make an assessment for what purpose and on what basis we could use your contact details. We will take into account the context in which this occurred and your reasonable expectations regarding our use of the personal data. If we consider that we have a legitimate interest in contacting you to request a quote, propose a partnership or offer you our product or service, you will always have the right to object to such use of your data,
In some cases, we may need to ask for your consent, and you will always be able to refuse to give it.
3.9. If you are applying for a job with us:
This means that you have expressed your desire to become our employee by concluding an employment contract with us. This can be done in two cases: ( first ) when you apply for a specific position advertised by us and accordingly send us your CV and/or cover letter or ( second ) when you send us your CV and/or cover letter without a specific advertisement, in order to we will contact you if there is a suitable vacancy.
In order to take steps to consider your application, we will review the information you have submitted. If we categorically judge that you are unsuitable, we will delete your personal data within 1 /one/ week of accepting our decision to do so, but no later than 2 /two/ months from the deadline for selection for the open position.
If you apply for a particular position, but for some reason we are unable to interview or hire you for it and we wish to retain your information for the future /for other suitable positions/, we will contact you to request your consent to this.
If you do not apply for a specific position from the outset, we will assume that you have an interest in our organization as a whole. For this, if we judge, we will retain your information in order to offer you work in the future based on our legitimate interest in selecting and hiring employees who have expressed an interest in our organization. In this case, we will keep your information for the period for which you yourself have expressed a desire, and if you have not specified one - for a period of up to 3 /three/ years.
During the period of your application with us, we will also collect additional information to assess whether we wish to enter into a contract with you, for example, information related to your interview, your tests, references that you have provided to us. When we determine that you are unsuitable, we will delete information about you.
Please do not provide us with any information that is not necessary for your application with us.
3.10. For what other purposes may we use your personal data?
We have described the most typical purposes for their processing above, but you should also consider the following purposes:
- for administration of our activity, including reporting and analysis in the company itself - our legitimate interest;
- prevention of fraud and other illegal and criminal activities - our legitimate interest;
- to establish and defend legal claims - our legitimate interest;
- to fulfill our obligations under a contract to which you are not a party - our legitimate interest;
- to analyze the effectiveness of our services and activities and their improvement - our legitimate interest.
- to fulfill our obligations under a contract to which you are a party;
- to fulfill our obligations applicable by law, for example accounting, tax and other obligations;
3.11. On what legal basis do we process your data?
3.11.1. Our legal obligation
These are the cases in which the processing of your personal data is necessary to comply with our legal obligation.
3.11.2. Our legitimate interest
When we define our legal basis as a "legitimate interest", we first assess what it is and whether the processing of your data is necessary to achieve it. We also assess whether your interests, fundamental rights and freedoms do not take precedence over it. Regardless of our discretion, you always have the right to object to processing based on legitimate interests, as described below in item 9.1.4.
3.11.3. Pre-contractual or contractual basis
When we need to take necessary steps, at your request, to conclude a contract between us or to fulfill a contract already concluded between us. In these cases, we will take care to process only your information necessary for the purpose.
3.11.4. Your agreement.
It is a freely expressed, specific, informed and unambiguous indication of your will, by means of a statement or a clear affirmative action, which expresses consent to the processing of your personal data for a specific purpose. If we have to process your "sensitive data" on the basis of your consent, the same should also be explicitly given. In item 9.1.7. you will find out how you can withdraw your consent at any time.
Note that consent is a different legal basis than those described above. For example, signing a contract between us is not equivalent to giving consent.
If you have concerns or doubts about what exactly is the applicable basis for a specific purpose of processing your data, you can always contact us.
You are obliged to provide us with your personal data in the event that such a contractual or legal obligation exists. If in such cases you do not provide us with this data upon request, we may not be able to enter into or perform the contract or realize any of the other purposes. In any case, we will notify you of this.
We may need to share your personal data with the parties listed below:
5.1. Within our group of related companies, as far as applicable – on the basis of our legitimate interest in administering and reporting our activities.
5.2. Service providers - processing personal data. These can be hosting companies, IT service providers, system administration, couriers, mobile operators. We conclude contracts with them that guarantee the security of your data.
5.3. Other personal data controllers who provide us with relevant services – banks, auditors, lawyers, professional consultants and insurers, event organizers and others – when this is necessary for our legitimate interest to provide us with a particular service.
5.4. Public authorities that require us to declare processing activities.
5.5. Third parties to/with whom we sell, transfer or merge parts of our business or our assets - when this is necessary in view of their legitimate interest to carry out an analysis of our activity and conclude the relevant transaction.
6.1. Your personal data is usually processed within the European Union or the European Economic Area and in rare cases is transferred to other countries ("third countries").
6.2. If it is necessary to transfer data to "another country", we guarantee that before such transfer the necessary level of data protection is ensured in the relevant third country or with the recipient in this third country. This may be based on a decision by the European Commission regarding the adequate level of data protection in a particular third country as a whole. Alternatively, the transfer of data may be based on the so-called "EU Standard Contractual Clauses" agreed with the recipient or, if the recipients are in the US, on the basis of the US-EU Privacy Shield Program ( EU-US Privacy Shield). Information about EU-US Privacy Shield participants can be found at www.privacyshield.gov/list. We will be happy to provide you with further information on suitable and relevant safeguards to maintain an appropriate level of data protection upon request.
We have implemented security measures to prevent the accidental loss, use, alteration, disclosure or access of your personal data without authorization. We also provide access to your personal data only to those employees and partners who have a specific business need to access such data.
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with legal, accounting, tax or reporting requirements.
When deciding on the exact period of data retention, we take into account its volume, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes of processing and whether they can be achieved by other means and legal requirements.
For tax purposes, we are required by law to keep basic information about our customers (including contact data, identity, financial data and transaction data) for five years /plus current/ after the relevant relationship has ended.
In many cases, we will comply with the statute of limitations under applicable law, for example, for bringing certain claims, which is in our legitimate interest.
In all cases, we take measures to restrict access to personal data at appropriate stages, in view of the ongoing processing of the data and the relevant purposes.
In some circumstances, we may anonymize your personal data for research, statistical or other purposes, in which case we may use this information for an unlimited period of time without further notice to you.
9.1. Under certain circumstances, by law, you have the right to :
9.1.1. request access to your personal information (commonly referred to as a "data subject access request"). This gives you the opportunity to obtain a copy of the personal information we hold about you and to check whether we are processing it lawfully.
9.1.2. request correction of the personal information we hold about you. This allows you to correct and update incomplete or inaccurate information we hold about you.
9.1.3. request deletion of your personal information. This gives you the opportunity to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You have the right to ask us to delete or remove your personal information also where you have exercised your right to object to processing (see below).
9.1.4. objections to the processing of your personal data when we base the processing on our legitimate interest (or that of a third party) and there are grounds relating to your particular situation. In addition, you have the right to object when we process your personal information for direct marketing purposes, including in cases of profiling.
9.1.5. request the restriction of the processing of your personal information. This allows you to ask us to stop processing personal information about you, for example, if you want us to establish the accuracy or basis for processing it.
9.1.6. request the transfer of your personal information to another party /right of portability/.
9.1.7. withdraw your consent - in case we process personal data on the basis of your consent or express consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before it is withdrawn.
You can also see more about these rights on the website of the Commission for the Protection of Personal Data.
9.2. Exercising Your Rights.
If you wish to exercise any of the rights set out above or receive more information about it, please send us an email at aleksandar.georgiev@easyconsult.eu, or send us a letter at our physical address listed in item 3.
You will not pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive, or excessive, or we will refuse to comply with your request in these circumstances.
We may need to ask you for specific information to help us verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure that ensures that personal data is not disclosed to a person who does not have the right to receive it. We may also contact you to request additional information regarding your request to expedite a response.
We try to respond to all legitimate requests within one month. Sometimes it may take us more than a month, in which case we will let you know.
If you are not satisfied with any aspects of how we collect and use your data, you have the right to lodge a complaint with the relevant competent Supervisory Authority. The Personal Data Protection Commission is the Supervisory Authority of the Republic of Bulgaria, defined by the Personal Data Protection Act as follows:
Address: Sofia 1592, Prof. Blvd. Tsvetan Lazarov” No. 2, GPS coordinates: N 42.668839 E 23.377495. Center for information and contacts - tel. 02/91-53-518. Email: kzld@cpdp.bg. Website: www.cpdp.bg
We would appreciate it if you would contact us first, in case of a complaint, so that we can try to help you.
We have the right to change and update this Policy. We will publish such changes on our website https://easyconsult.eu/ If these changes are material, we will further inform you about this by email or other appropriate means of contacting you.
Mediation
MEDIATION IN RECRUITMENT AND SELECTION OF PERSONNEL
Applicable from: May 2018
This Policy explains how we collect and process your data in connection with our recruitment, staffing, and related services /also referred to as "services" or "our services". If you use or visit any of our websites, or have any other relationship with us, please also familiarize yourself with Easy Consult OOD's General Privacy Policy on this page.
1.1. What are employment placement services?
- informing and/or consulting job seekers and employers;
- psychological support for job seekers;
- referral to adult education;
- guidance and support for starting work, including in another populated place in the country or in other countries;
1.2. What exactly does recruitment mean?
- this is a service that we provide to the Employers with whom we have concluded contracts and consists in assessing the compliance of given job candidates with the Employer's requirements for occupying a certain position /job/.
3.1. Our responsibility
We, "EASY CONSULT" LTD / EASY CONSULT, EIC: 115829812, registered office and address of management: city of Sofia, the district "Mladost", g.k. "Mladost 4", Business Park Sofia, Building 15, ground floor, we are the Administrator regarding your personal data and are responsible for them.
You can contact us at the above address as well as by e-mail: dpo@easyconsult.eu
We have appointed a Personal Data Protection Officer. Contact: e-mail: dpo@easyconsult.eu.
It is important that the information we have about you is accurate and up-to-date. It is especially important that you inform us if you change your email, telephone or address, because it may be that someone else receives your correspondence.
3.2. Responsibility of the Employer
Our services help you find work with Employers who are looking for employees. Where your personal data is transferred to such an Employer through us, it is also responsible for it as a Personal Data Controller. There is no obstacle to contacting the Employer in relation to your personal data or specific questions, but you can always use us as a point of contact regarding the processing of your data by the Employer in the process of applying to him.
4.1. Initial information when applying for a position.
Most often, you come into contact with us on the occasion of an advertisement published by us for an open position with our client - Employer.
By applying for this position, you are sending us certain information, which we call Initial Position Application Information. Most often, it is contained in your CV /autobiography/, which you comply with the requirements of the advertisement. These are usually: Identifying data: Your names, age; Your contact details: address, e-mail, telephone; Data on your education and professional qualifications: type and degree, specialty, duration, data on acquired qualifications; Information on language proficiency and other skills: language, level, computer skills, other skills related to the position offered. Data about your experience: information about the activity you performed in the past - identical or similar to the position offered; Cover letter data: we may sometimes require such information to assess what motivates you for the job offer; Other data relevant to the specific position offered.
We process Initial Information when applying for a position to PRE-SELECT applicants, i.e. to assess whether you are a suitable candidate for the conditions of the position with the Employer based on the information you have sent. If we decide that this is the case, we will offer you to enter into an intermediary contract (intermediary services) with us. This is a mandatory condition according to Bulgarian legislation in order to connect you with the relevant Employer. We may not be able to offer you our placement services simply because the position has been filled or withdrawn by the Employer in the meantime, i.e. the position is "closed".
4.1.1. How do we proceed from here?
(a) If we consider that you are not suitable for the position or if a position is "closed" in the meantime, we will not provide your personal data to the Employer. However, we will retain your Initial Position Application Information in our database for a period of no longer than 24 months to check for other similar positions matching your professional profile. For this purpose, we refer to our legitimate interest in seeking to connect the right employers with the right candidates . In order to offer you our brokerage services, we will contact you with a view to concluding a brokerage contract.
If you object to us retaining your Initial Information when applying for a position for this purpose, you may object to its retention at any time and we will comply immediately. You can make this objection already with your application for the specific advertisement, by writing in any of the documents you send or in a message to us: I OBJECT YOU OFFERING ME OTHER POSITIONS or any other text with such a meaning.
You should not worry about us posting ads for non-existent positions because by law we are only required to post ads if we have a request from an Employer. We comply with this requirement.
(aa) In some cases, we will retain your Initial Information when applying for a position in our database to check for other similar positions matching your job description, based on your consent that we request from you. In the event that we have requested your consent and you do not provide it, we will not retain your information for this purpose, i.e. in this case we will not invoke our legitimate interest as described in point (a).
(aaa) We may consider that your profile does not match the profile of the Employers who are usually our customers. In these cases, we will delete your personal data as soon as we make this assessment.
(b) If we consider that you are suitable for the position and the position is "open", we will invite you to an interview or refer you directly to an interview with the Employer. Accordingly, we will offer you to enter into an Agreement for mediation services. In all cases where such a contract has been concluded between us, your personal data, which are necessary for the performance of the contract by us, will be processed on the basis of this contract.
4.2. What will we do if you have sent us your CV and/or other documents without applying for a specific position?
In this case, we will include you in our database to check for positions matching your professional characteristics. For this purpose, we refer to our legitimate interest in seeking to connect the right employers with the right candidates . In order to offer you our mediation services, we will contact you with a view to concluding a mediation contract.
4.3 . What will we do if we receive information about you from a third party?
We aim to get information about candidates directly from them. For this we always advise people who want to refer their friends, acquaintances or others to us and our services to give our contacts and the candidate to contact us. However, there are situations where we may have received such information about you from another person. We will consider all the circumstances and will either (a) take action to delete your information, for example, if we believe we received it in error, or (b) contact you to notify you of the receipt of this data and for this policy. We will give you the opportunity to confirm that you really want us to provide you with services, and accordingly we will offer you the conclusion of a mediation contract. If it turns out, that the sending of this information to us was unwanted, or in the process of contacting us you state that you do not wish us to provide you with any services, we will delete your personal data. It is also possible in this case that we retain certain information about you, for example, in view of our legitimate interest to protect our rights and legitimate interests in the event of a legal or extrajudicial dispute.
4.4. How will we provide you with our mediation services?
In all cases where we agree to provide mediation services to you, we shall enter into the aforementioned mediation agreement. This is related to the processing of your personal data, in order to provide you with the relevant service, as well as to comply with the legal requirements applicable to us, for example: * the table at the end of the text
4.4.1. Relations with potential employers
When you apply for a specific position or we refer you to a specific position, it means that we have concluded an agency contract with a specific employer and they have given us a request to find an employee/s for them. In this case, there is also another compatible purpose for us to process your personal data, namely - to provide an intermediary service to the Employer himself for the selection of candidates and their hiring to an employment contract by the Employer. At the same time, obtaining /realizing/ this service is the purpose for which the Employer processes your personal data.
4.5. Legitimate interests
In some cases, we will also use your personal data for other legitimate interests of ours or of a third party, which at the same time represent the purposes of the respective processing:
- to develop our activity as an intermediary for employment;
- for administration and activity reporting;
- to contact you;
- to protect our rights and legal interests in the event of a legal and extrajudicial dispute, including in connection with our mediation agreement with the Employer;
- for statistical purposes;
- for the legitimate interest of the employer to be informed and consulted when hiring employees;
- to make an accurate assessment of your qualities as a user of our intermediary services;
4.6. Our legal obligations
In some cases, we process your personal data in order to fulfill a legal obligation applicable to us, such as tax, accounting obligations, as well as our obligations in relation to the Employment Promotion Act.
4.7. your profile
Please keep in mind that the services we provide are specific and require the collection and processing of a relatively large volume and various personal data about you. This often requires us to create your profile, as our client - a natural person, so that we can provide you with our services and comply with your wishes, with your work characteristics /education, qualifications and others/. In this way, we will be able to connect you with the suitable and desired employers. The profile includes an analysis of the information we have about you, as well as our description of you as a potential employee and/or for a specific position, according to the Employer's requirements. We share information from your profile with employers in view of their legitimate interest in selecting for them a suitable employee for the relevant position,
4.8. Your consent
In some cases, we will process your personal data on the basis of your consent, which we will ask you to give us. You should know that giving consent is always your free choice. There are some cases where your failure to consent could mean that we will not be able to provide you with a particular service. For example, we may ask you for your consent to process your health information that is necessary in order to apply for a particular position. Failure to give us such consent may terminate your application process.
In the event that we process personal data on the basis of your consent or express consent, you have the right to withdraw your consent at any time without prejudice to the lawfulness of the processing based on consent before it is withdrawn.
4.9. Special categories of personal data
Special categories of data, or "sensitive data", are those revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the sole purpose of identifying an individual, health data condition, sex life or sexual orientation.
In general, we do not collect and process special categories of personal data, but in some cases this may be necessary in connection with our services that you use. For example, we may need to process information about your health that is relevant to your job application. In such cases, we will ask you for your express consent. Please do not provide special categories of personal data without first giving your express consent.
In the event that we process personal data on the basis of your consent or express consent, you have the right to withdraw your consent at any time without prejudice to the lawfulness of the processing based on consent before it is withdrawn;
4.10. Are you obliged to provide us with your personal data?
Where we are required to collect personal data by law or under the terms of the contract between us and you do not provide us with this data upon request, we may not be able to perform the contract (for example, to present your application to a potential employer). If you do not provide us with the requested data, we may not be able to perform the service you have requested, but if we do, we will notify you.
4.11. More information about the purposes for using your data.
We will only use your personal data for the purpose or purposes for which it was collected or, if necessary, for a compatible purpose. For more information, please write to us at dpo@easyconsult.eu. In the event that we need to use your data for an unrelated new purpose, we will notify you and explain the legal grounds for processing.
4.12. Using your data without your consent or knowledge.
We may process your personal data without your knowledge or consent only when required or permitted by law.
4.13. Unsolicited information
Sometimes you provide us with information that we do not need in view of the purpose. We advise you not to do this. Although we will take care of this information, you may be putting your privacy at unnecessary risk by sharing such information.
Our legal basis for processing your personal data in order to send you marketing communications is your consent or our legitimate interests (namely to develop our business as a recruitment agent), and these communications may include information about our seminars , events, trainings and others.
Before we share your personal data with any third party for their marketing purposes, we will ask for your consent.
5.1. How to opt out of our marketing communications?
You may opt out of receiving marketing communications by following the opt-out links in any marketing communications sent to you OR by emailing us your opt-out at [dpo@easyconsult.eu] at any time.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data that you have provided to us on another legal basis /for example, in connection with our legal obligation or on a contractual basis/.
We mainly receive data from you. But it is also possible for us to receive data from other persons, for example from the Employer with whom you went for an interview and/or hired you, through the use of our services. In some cases, we may collect information about you from public sources, as well as from your profiles on the Internet /for example on LinkedIn, if the legitimate interest we refer to /to make an accurate assessment of your qualities as a user of our intermediary services/ is not dominated by your interests, fundamental rights and freedoms.
7.1. Employers.
In order to fulfill the mediation agreement with you, as well as the one with the Employer, we will transfer your data, including the data from your Profile, to the Employer offering the relevant position - the position for which you specifically apply in an advertisement or a position suitable for you, in in case you are generally looking for work through us. Before we pass your personal data to an Employer who is not specifically identified at the time of your application for a particular position, we will provide you with such identifying information about them, unless you have authorized/directed us to provide your personal data to all Employers, to which we consider, for example.
7.2. Other persons
Outside of your potential Employer, we may share your personal data with the parties listed below:
7.2.1. Within our group of related companies, as far as applicable – on the basis of our legitimate interest in administering and reporting our activities.
7.2.2. Service providers - processing personal data. These can be hosting companies, IT service providers, system administration, couriers, mobile operators. We conclude contracts with them that guarantee the security of your data.
7.2.3. Other personal data controllers who provide us with relevant services – banks, auditors, lawyers, professional consultants and insurers, event organizers and others – when this is necessary for our legitimate interest to provide us with a particular service.
7.2.4. Public authorities that require us to declare processing activities, for example the Employment Agency and the Labor Inspectorate, which have powers in relation to our activity as an employment agency.
7.2.5. Third parties to/with whom we sell, transfer or merge parts of our business or our assets - when and to the extent necessary for their legitimate interest to analyze our activity and conclude the relevant transaction.
Personal data are usually processed within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries ("third countries").
8.1. Transfer of personal data to a "third country".
If we transfer your personal data to a "third country", we ensure that prior to such transfer the necessary level of data protection is ensured in the relevant third country or with the recipient in that third country. This may be based on a decision by the European Commission regarding the adequate level of data protection in a particular third country as a whole. Alternatively, the transfer of data may be based on the so-called "EU Standard Contractual Clauses" agreed with the recipient, or if the recipients are in the US - based on compliance with the terms of the privacy protection program between USA and EU. We will be happy to provide you with further information on suitable and relevant safeguards to maintain an appropriate level of data protection upon request.www.privacyshield.gov/list .
We have implemented security measures to prevent the accidental loss, use, alteration, disclosure or access of your personal data without authorization. We also provide access to your personal data only to those employees and partners who have a business need to access such data. They will process your personal data only on our instructions and they must keep it confidential.
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with legal, accounting, tax or reporting requirements.
When deciding on the exact period of data retention, we take into account its volume, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes of the processing if they can be achieved by other means and legal requirements.
In some circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information for an unlimited period of time without further notice to you.
11.1. In certain circumstances, by law, you have the right to:
11.1.1. request access to your personal information (commonly referred to as a "data subject access request"). This gives you the opportunity to obtain a copy of the personal information we hold about you and to check whether we are processing it lawfully.
11.1.2. request correction of the personal information we hold about you. This allows you to correct and update incomplete or inaccurate information we hold about you.
11.1.3. request deletion of your personal information. This gives you the opportunity to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You have the right to ask us to delete or remove your personal information also where you have exercised your right to object to processing (see below).
11.1.4. objections to the processing of your personal data when we base the processing on our legitimate interest (or that of a third party) and there are grounds related to your particular situation. In addition, you have the right to object when we process your personal information for direct marketing purposes, including in cases of profiling.
11.1.5. request the restriction of the processing of your personal information. This allows you to ask us to stop processing personal information about you, for example if you want us to establish the accuracy or basis for processing it.
11.1.6. request the transfer of your personal information to another party /right of portability/.
11.1.7. withdraw your consent - in case we process personal data on the basis of your consent or express consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before it is withdrawn.
You can also see more about these rights on the website of the Commission for the Protection of Personal Data.
11.2. Exercising Your Rights.
If you wish to exercise any of the rights set out above or receive more information about it, please send us an email at dpo@easyconsult.eu, or send us a letter at our physical address listed in point 3.
You will not pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive, or we will refuse to comply with your request in these circumstances.
We may need to ask you for specific information to help us verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure that ensures that personal data is not disclosed to a person who does not have the right to receive it. We may also contact you to request additional information regarding your request to expedite a response.
We try to respond to all legitimate requests within one month. Sometimes it may take us more than a month, in which case we will let you know.
If you are not satisfied with any aspects of how we collect and use your data, you have the right to lodge a complaint with the relevant competent Supervisory Authority. The Personal Data Protection Commission is the Supervisory Authority of the Republic of Bulgaria, defined by the Personal Data Protection Act as follows:
Address: Sofia 1592, Prof. Blvd. Tsvetan Lazarov” No. 2, GPS coordinates: N 42.668839 E 23.377495. Center for information and contacts - tel. 02/91-53-518. Email: kzld@cpdp.bg. Website: www.cpdp.bg
We would appreciate it if you would contact us first, in case of a complaint, so that we can try to help you.
We have the right to change and update this Policy. We will post such changes on our website www.easyconsult.eu. If these changes are material, we will further inform you about this via your email or other appropriate means of contacting you.
POLICY FOR THE PROTECTION OF PERSONAL DATA OF WORKERS/TEMPORARY EMPLOYEES
INTRODUCTION
We, "EASY CONSULT" LTD / EASY CONSULT, EIC: 115829812, registered office and address of management: city of Sofia, the district "Mladost", g.k. "Mladost 4", Business Park Sofia, Building 15, ground floor ("we" or "us") take the privacy of your privacy and the security of your personal data very seriously.
In this Policy, we explain to you how we collect and use your personal data before, during and after the termination of your relationship with us under an employment contract for temporary work in accordance with the General Data Protection Regulation (GDPR) and is in connection with our activity as an Enterprise that provides temporary work. We, "EASY CONSULT" LTD, are the Administrator regarding your personal data and are responsible for them. The policy applies to all current and former temporary employees and is not part of an employment contract or other contract for services with us.
It is very important that the information we have about you is correct and up-to-date. Please inform us of any changes or if you notice any errors.
We may update this Policy at any time. Sometimes we may also provide you with additional notices about how your personal data is processed.
DATA PROTECTION PRINCIPLES
We are committed to complying with data protection legislation, including the six principles of the GDPR, which are:
RESPONSIBILITY OF THE COMPANY USER
As an enterprise that provides temporary work, we conclude an employment contract with you, under which you work in the user Enterprise - under its management and control. When such an employment contract is concluded with you, your personal data is processed both by us and by the User Enterprise and the latter is also responsible for them as a Personal Data Administrator. If you have any questions about how personal data is processed, you can contact us or the User Enterprise.
PERSONAL DATA WE PROCESS
"Personal Data" means any information about an individual that can identify that individual, as well as any other information relating to an identified individual. Anonymous information does not constitute personal data. There are "special categories" of more sensitive personal data that require a higher level of protection, such as your ethnicity and whether you are a member of a trade union.
We collect, store and use personal data about you, and a large part of this information is in connection with your daily interaction with the User Enterprise. Such data are, for example:
We may also collect, store and use the following "special categories" of more sensitive personal information:
HOW WE COLLECT PERSONAL DATA
We collect personal data about you in the recruitment process, for example directly from you or from the User Enterprise itself. We may sometimes collect additional information from professional sites, such as LinkedIn.
During the validity of the contract, we receive personal data from: yourself, the User Company, from third parties, for example, customers of the User Company, with whom you are in contact.
HOW WE USE YOUR PERSONAL DATA
We will only process your personal data if we have a legal basis to do so. We will most often use your personal data in the following circumstances:
We may also use your personal data in the following situations, although very rarely applicable in practice:
PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
We will process your personal data for the following purposes:
If you choose not to provide us with certain personal data that we have requested, we may not be able to fulfill our arrangements with you (for example, to pay you remuneration or compensation) or you may prevent us from complying with our legal obligations (for example, to issue you and provide certain documents certifying facts related to the employment relationship).
Sometimes we may use your personal data without your knowledge or consent when required or permitted by law.
HOW WE USE SENSITIVE DATA
"Special categories" of personal data require higher levels of protection than non-sensitive data. In order to process such sensitive data, we must have an additional basis /condition/. We may process special categories of personal data in the following circumstances:
We may sometimes process sensitive personal data where this is necessary in connection with legal claims; where it is necessary to protect your vital interests (or the interests of another person) and you are unable to give your consent; in cases where you have already provided the information publicly.
We will use your sensitive personal data in the following ways:
JUDICIAL /CRIMINAL/ PAST
We may only process data relating to criminal convictions where the law allows us to do so.
AUTOMATED DECISION MAKING
Automated decision making occurs when an electronic system uses personal information to make a decision without human intervention. We have the right to use automated decision-making in the following circumstances:
If we make an automated decision based on particularly sensitive personal information, we must have your express written consent or it must be based on public interest, and again we must have implemented appropriate measures to protect your rights.
You will not be subject to decisions that have a significant impact on you based solely on automated decision-making, unless we have a legal basis to do so, and we should notify you accordingly.
DISCLOSURE OF YOUR DATA OUTSIDE OUR COMPANY
We exchange information about you primarily with the User Enterprise where you work to fulfill our obligations/exercise our rights under our contract with you, under our contract with the User Enterprise and by law.
We may need to share your personal data with other third parties, including service providers, for example because we need to administer our employment relationship with you or where we have other legitimate interests in this regard. These can be accounting firms, lawyers, auditors and other organizations that provide services to us.
We may also transfer your personal data to other entities in our group of companies /including owners/ as part of our regular reporting activities for company representation, in the context of a business reorganization or group restructuring, for system maintenance and data hosting .
We may share your personal information with other third parties, for example in the context of a possible sale or restructuring of the business. We may also need to share your personal information with a government regulator or other legal requirement.
These persons are required to keep your personal data confidential and secure.
INTERNATIONAL DATA TRANSFER
Your personal data is usually processed within the European Union (EU) or the European Economic Area (EEA).
If we transfer information to "third countries" /outside the EU and EEA/, we ensure that prior to such transfer the necessary level of data protection is ensured in the relevant third country or with the recipient in that third country. This may be based on a decision by the European Commission regarding the adequate level of data protection in a particular third country as a whole. Alternatively, the transfer of data may be based on the so-called "EU Standard Contractual Clauses" agreed with the recipient, or if the recipients are in the US - based on compliance with the terms of the privacy protection program between US and EU (EU-US Privacy Shield). We will be happy to provide you with further information on suitable and relevant safeguards to maintain an appropriate level of data protection upon request. www.privacyshield.gov/list.
DATA SECURITY
We have implemented appropriate security measures to prevent your personal information from accidental loss, unauthorized use or access, alteration or disclosure.
We have procedures in place to deal with any suspected data security breach and will notify you and any relevant Supervisory Authority where we are legally required to do so.
DATA STORAGE
We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of legal, accounting or reporting requirements.
For tax purposes, we are required by law to keep basic information (including contact data, identity, financial data and transaction data) for five years /plus current/.
We are required by law to keep payroll records for a period of 50 years from the 1st January following the reporting period to which they relate.
In many cases, we will comply with the statute of limitations under applicable law, for example, for bringing certain claims, which is in our legitimate interest.
To determine an appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these purposes through other means, and take into account applicable legal requirements.
In all cases, we take measures to restrict access to personal data at appropriate stages, in view of the ongoing processing of the data and the relevant purposes.
In some circumstances, we may anonymize your personal information so that it can no longer be linked to you, in which case we may use that information without further notice to you.
Upon termination of our relationship with you, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
RIGHTS OF ACCESS, CORRECTION, DELETE AND RESTRICTION, PORTABILITY
It is important that the personal data we have about you is accurate and up-to-date. In many cases, this is essential to you and your rights. Please inform us if your personal information changes.
Under certain circumstances, by law, you have the right to :
You can also see more about these rights on the website of the Commission for the Protection of Personal Data.
If you wish to exercise any of your above rights, please email us at dpo@easyconsult.eu or submit your request in writing to our address. We will assist you in formulating your requests, including providing you with relevant forms to facilitate the process.
You will not pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive, or we will refuse to comply with your request in these circumstances.
We may need to ask you for specific information to help us verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure that ensures that personal data is not disclosed to a person who does not have the right to receive it. We may also contact you to request additional information regarding your request to expedite a response.
We try to respond to all legitimate requests within one month. Sometimes it may take us more than a month, in which case we will let you know.
If you are not satisfied with any aspects of how we collect and use your data, you have the right to file a complaint with the Commission for the Protection of Personal Data - the Supervisory Authority of the Republic of Bulgaria, established by the Law on the Protection of Personal Data, as follows:
Address: Sofia 1592, Prof. Blvd. Tsvetan Lazarov” No. 2, GPS coordinates: N 42.668839 E 23.377495. Center for information and contacts - tel. 02/91-53-518. Email: kzld@cpdp.bg. Website: www.cpdp.bg.
We would appreciate it if you would contact us first, in case of a complaint, so that we can try to help you.
RIGHT TO WITHDRAW CONSENT
In the few cases where you may have provided your consent to the collection, processing and transfer of your personal information for a particular purpose, you have the right to withdraw your consent to that particular processing at any time. To withdraw your consent, please contact us as set out above in relation to your other rights. Once we receive notice that you have withdrawn your consent, we will no longer process your information for the purpose or purposes for which you originally consented, unless we apply another legal basis of which we will notify you. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before it was withdrawn.
YOUR CONTACT WITH US IN CONNECTION WITH YOUR PERSONAL DATA
If you have any questions about this Policy and how we process your personal data, please contact us by email: dpo@easyconsult.eu
Cookies
This website uses a limited number of cookies to make your browsing experience easier. A "cookie" is a small text file that the site transfers to your computer's hard drive for the duration of the session or permanently. "Cookies" allow anonymous information about your actions and preferences on the site to be saved (for example, font size, language and other settings). "Cookies" are used for several purposes - functional (to make the website function properly), analytical (to anonymously track traffic to the website) and marketing (to improve promotions related to the site).
When created, cookies usually do not contain any personal information. They don't scan your computer. Any personal information they may contain is the result of your own contribution to the website form. When a cookie stores personal information, that information is encoded in such a way that it is unreadable to any third party who accidentally accesses your cookie folder. The only computer that can read and decode the information is the server that created the cookie.
What cookies do we use on this website?
Session cookies
These are temporary cookies that remain in your web browser's cookie file only for the duration of your visit and are deleted when you close the browser. The purpose of these cookies is functional.
"Cookies" from third parties
These are cookies placed by external providers such as Google Analytics and Facebook. They can be sessional or permanent, and their purpose is analytical and marketing. The website administrator has no control over these cookies.
What to do if you do not want cookies?
If you would like to obtain further information about cookies, please visit http://www.allaboutcookies.org/ .
This website uses a limited number of cookies to make your browsing experience easier. A "cookie" is a small text file that the site transfers to your computer's hard drive for the duration of the session or permanently. "Cookies" allow anonymous information about your actions and preferences on the site to be saved (for example, font size, language and other settings). "Cookies" are used for several purposes - functional (to make the website function properly), analytical (to anonymously track traffic to the website) and marketing (to improve promotions related to the site).
When created, cookies usually do not contain any personal information. They don't scan your computer. Any personal information they may contain is the result of your own contribution to the website form. When a cookie stores personal information, that information is encoded in such a way that it is unreadable to any third party who accidentally accesses your cookie folder. The only computer that can read and decode the information is the server that created the cookie.
What cookies do we use on this website?
Session cookies
These are temporary cookies that remain in your web browser's cookie file only for the duration of your visit and are deleted when you close the browser. The purpose of these cookies is functional.
"Cookies" from third parties
These are cookies placed by external providers such as Google Analytics and Facebook. They can be sessional or permanent, and their purpose is analytical and marketing. The website administrator has no control over these cookies.
What to do if you do not want cookies?
If you would like to obtain further information about cookies, please visit http://www.allaboutcookies.org/.
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