POLICY FOR PROTECTION OF PERSONAL DATA (PRIVACY POLICY)

FOR COMPANIES

 

This Personal Data Protection Policy (Privacy Policy) is accepted by "WORKTALENT" Ltd., a company registered in the Commercial Register and the Register of Non-Profit Legal Entities at the Registry Agency with UIC 207559325, with registered office and management address: 19, Knyaz Aleksandar Dondukov - Korsakov, 4th floor, Sofia. The use of the expressions „we“, „us“, „our“ also refers to „WORKTALENT“ Ltd.

„WorkTalent” Ltd. is a personal data controller within the meaning of the applicable legislation in the field of personal data protection and administers WorkTalent.com website.

 

І. Subject

The main purpose of this Privacy Policy is to indicate which personal data provided to us by the Companies is processed within the services provided on the Internet portal WorkTalent.com (hereinafter referred to as the Portal or Platform), for what purposes and on what grounds we carry out this processing, as well as to provide additional information and assistance in this regard.

If you have any questions to us regarding the protection of your personal data, you can use the contact information provided at the end of this Privacy Policy.

Please read this Policy carefully before using our services. It is important to know that:

- By registering on the Portal and performing certain actions in the registration process, you agree to the General Rules for the use of the portal "WORKTALENT", the General Terms and Conditions for the use of the services of the portal "WORKTALENT" by Companies and this Policy and confirm that you accept them. By doing so, you enter into a contract with us for the services we provide.

- The provision of the mandatory personal data is voluntary in order to use or access the services of the Portal. These mandatory data are defined by us as the minimum necessary to be able to provide you with our services, respectively - to be able to provide services to the Applicants looking for a job or internship through the offers published on the Portal.

 

II. Definitions

1. Personal data - any information relating to a specific natural person (individual) who is identified or identifiable;

2. Processing of personal data - any activity that takes place in relation to personal data, including storage, use, recording, organisation, adaptation, transmission, disclosure, combination, erasure, etc.;

3. Personal data controller - the person who determines the purposes and means of processing personal data;

4. Portal - www.WorkTalent.com (including front page and subpages);

5. Ground for processing personal data (ground) - a condition that must be met in order for processing of personal data to be lawful.

The terms "User", "Visitor", "Applicant" and "Company" in this Policy shall have the meanings ascribed to them in the General Terms and Conditions of Use of the WORKTALENT Portal.

 

III. Types of Personal Data Subjects, Categories of Data Processed, Purposes of Processing and Ground, Storage Period

Our users visit and use the Portal and the services provided by us in different ways, which is why we have identified several categories of users. For each of them we have defined the respective volume of data we collect and process, purposes and grounds, storage periods, etc. The same user may fall into more than one category.

The data that may be collected about visitors, automatically for all users (registered and unregistered), and specifically for registered Applicants is set out in the Privacy Policy for Individuals - Applicants and Visitors.

The main purpose of this Privacy Policy is to indicate which personal data provided to us by the Companies is processed within the services provided on the WorkTalent.com Internet portal (hereinafter referred to as the Portal or Platform), for what purposes and on what grounds we carry out this processing, as well as to provide additional information and assistance in this regard.

1. Data subjects (natural persons):

1.1. Legal representatives of the Companies - legal entities

1.2. Natural persons - employers

1.3 Contact persons, employees or persons responsible for the protection of the personal data of Applicants designated by the Companies;

1.4. Individuals whose data is contained in the User Content.

2. Mandatory data:

In connection with the use of the SERVICES, the Companies register their user account and offers, in which they can indicate personal data of their legal representatives, employees, contact persons, persons responsible for the protection of the personal data of the Applicants, namely - names, addresses, telephone numbers, data on positions held, email addresses, photo/video images.

Companies shall ensure and guarantee that they have a valid legal basis to publish/provide personal data of data subjects under this Policy in user accounts, in offers and in other materials in the Company's supplementary presentation modules, and that such persons are accordingly familiar with this Policy.

In addition to the above data, WORKTALENT processes information to confirm acceptance of the General Terms and Conditions of Use of the WORKTALENT Portal, the General Terms and Conditions of Use of the WORKTALENT Portal Services by Companies and this Policy (date, time and IP address), as well as other personal data in connection with the interaction with Data Subjects in relation to the Services and the Portal.

Optional data: Any personal data concerning the above Data Subjects that the Company or the Data Subjects themselves may provide at their own will and discretion when creating the account, posting the offer or exchanging messages with WORKTALENT.

Companies are not permitted to store in their user account or to provide in any form special or sensitive categories of personal data concerning the above Data Subjects or other persons revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying an individual, data concerning health or data concerning sex life or sexual orientation of the natural person. Such data should be removed from the Platform, and WORKTALENT reserves the right (but not the obligation) to also remove such data.

Purposes of processing:

a) Purposes of processing related to and/or necessary for the conclusion and performance of a contract with the Company where the Company is an individual:

- Registration of a account, respectively - publication of an offer enabling the use of the SERVICES of the Portal and the maintenance of a user account,

- Provide the SERVICES available through the Portal, including to provide various functionalities;

- Communication, including electronic communication, regarding the SERVICES provided;

- The storage of certain log files is necessary for the actual provision of the SERVICES;

b) Purposes of processing necessary for compliance with legal obligations:

- Fulfillment of requests from public authorities to provide information;

- Compliance with the obligation to keep information on the time and source of the electronic statements transmitted (under the Law on electronic document and electronic authentication services);

- Compliance with other legal obligations and requirements (e.g. under the Law on Electronic Communications)

- Compliance with tax and accounting legislation;

c) Purposes of processing personal data related to the legitimate interests of the Controller or of third parties:

- Evidence of any statements made and other actions taken by the Company in the creation and management of an account, respectively - in the posting of an offer, and the use of the SERVICES (including through the collection and storage of log files);

- Ensuring the normal functioning and use of the Portal;

- Communication, including electronic communication, regarding the SERVICES provided;

- Protecting the rights and legitimate interests of WORKTALENT and its partners/other 3rd parties against claims.

- Providing the Services to Companies, which inevitably requires interaction with Data Subjects.

d) Purposes for which the Data Subject has given his/her explicit consent:

This is a freely given, specific, informed and unambiguous indication of the Data Subject's will, by means of a statement or a clear confirmatory action, which expresses consent to the processing of his/her personal data for a specific purpose.

Consent is a different legal ground from those described above. For example, entering into a contract is not equivalent to giving consent.

If a Data Subject has concerns or doubts about what exactly is the applicable ground for a particular purpose of data processing, they can always contact us.

Storage period: for the entire period of existence of the the user account, respectively - of the publication of each offer. The company can send a request to remove the registered account to the e-mail: contact@worktalent.com.

Upon removal of the account, the data contained therein is deleted from the Portal and is not accessible to other users. They will be retained by WORKTALENT for a period of 1 (one) year after removal - for the purpose of resolving potential disputes and to comply with our legal obligations, after which they will be completely removed. Some data will also be retained for a longer period, including up to six (6) years, in order to comply with tax obligations and to protect WORKTALENT from potential disputes, accordingly we will comply with the relevant statute of limitation periods under applicable law. 

IV. Posting, modifying and deleting User Content on the Portal.

The Companies publish user content on the Portal . User Content may contain personal data (including such of third parties) and the relevant Company is solely responsible for the lawful processing of the data contained in its User Content. WORKTALENT has no obligation to monitor the accuracy of User Content and shall not be liable if such User Content violates the law or infringes the rights of other persons.

The provisions of this section will also apply to the articles published in the Paid Modules of the Portal - when they contain personal data provided by the Companies.

Purposes of processing necessary for compliance with legal obligations:

- Taking measures to prevent/remove illegal content;

- Fulfillment of requests from public authorities to provide information;

- Compliance with other legal obligations.

Purposes of the processing related to and/or necessary for the performance of a contract with the data subject:

- Provision of the information services available through the Portal.

Purposes for processing personal data necessary for the purposes of the legitimate interests of the Company or of third parties:

- Evidence of any statements made and other actions taken by the user in creating and managing a user account and using the SERVICES;

- Ensuring the normal functioning and use of the Portal;

- Protection of the rights and legitimate interests of the Administrator and its partners/other 3rd parties against claims;

- Provision of the Services through the Portal;

- Legitimate interests of Companies to publish certain User Content through the Portal.

Storage period: for the entire period of availability of the User Content on the Portal, and for a longer period - for tax, accounting and legal defense purposes in the event of disputes and claims against WORKTALENT or the Companies.

V. Additional information

Personal data may be used for the purpose of direct marketing of our services and services of our partners, as well as for the provision of other additional services.

We process the data we collect from log files, cookies and web beacons for the following purposes: to provide you with access to the Portal; to personalize advertisements of our products and of our partners' products; to measure and track statistical dependencies in order to improve the quality of the SERVICES and therefore the interest in them.

The IP address recognition and collection is carried out for the following purposes: disclosure of the identity of users of the Portal, in compliance with the law and regulations, to protect our rights and legitimate interests; to analyze traffic to the Portal and to prevent malicious attacks; display offers and information related to your location, service information. We carry out these actions on the ground of our legitimate interests to develop our business and to protect our rights and legitimate interests in the event of disputes, and in certain cases on the ground of the mandatory prescriptions of the law.

In certain circumstances, we may use your personal data to protect our rights and legitimate interests and the rights and legitimate interests of third parties, for example in the event of litigation or out-of-court dispute.

NB! An important requirement for consent to the processing of personal data of persons under the age of 16, where this is permissible, is that the consent is given by the person's parent, guardian or custodian.

VI. Who has access to your personal data and how we protect your personal data

Maintaining the privacy and security of your personal data is of the utmost importance to us. In this regard, access to your personal data is only granted to the following categories of persons to the extent necessary to fulfil the above purposes for which we process your personal data:

- Our employees and persons engaged under a non-employee contract to perform certain work related to the SERVICES.

- Persons providing hosting services (servers) for our websites and other technical services for the maintenance of our systems (including their employees and subcontractors), for which purpose we have entered into the necessary contract with the data processor under the current regulations;

- Professional consultants (lawyers, accountants, etc.) as necessary to implement and protect our rights and legal interests.

- State authorities, at their request, in connection with the performance of their public powers granted to them by Bulgarian law, as well as when taking action to protect our rights and legitimate interests.

In order to ensure the security of the Portal, the personal data you provide us when registering your account is protected by SSL (Secure Socket Layer) technology, a method of encrypting personal data. The password you provide when registering on the Portal is encrypted to ensure protection against unauthorised access to your account.

While we make every effort to protect your personal information, you should be aware that the transmission of information over the Internet can never be completely secure.

 

VII. Periods for which we store your personal data

We store your personal data for as long as necessary to ensure the effective functioning of the Portal, the performance of contracts concluded by us (including those arising from the acceptance by users of the General Terms and Conditions for the use of the services of the portal "WORKTALENT") and the realization of our legitimate interests. Specific storage periods for certain categories of data are set out in the relevant places in this Policy. Please contact us for further information if you have a question about a specific storage period.

It is important to know that at any time you may opt out of the use of the SERVICES, as well as withdraw the consents provided for the use of your personal data - where consent is the groundfor processing. In these cases, we will cease using your data, and providing our SERVICES to you, to the extent possible.

In certain cases, even if the use of your personal data has been discontinued due to the deletion of an account or due to the explicit withdrawal of consents provided by you, we may store an archive of your personal data, to the extent necessary to protect our rights and legitimate interests, for a period until the expiration of statute of limitation periods provided for in applicable law. Generally, these periods are 5 years, but may be shorter or longer in certain circumstances.

You should be aware that your IP address is automatically collected whenever you visit the Portal, regardless of whether you have opted out of our SERVICES. In these cases, if you do not want us to have access to your IP address, you should not visit the Portal.

 

VIII. Your rights in relation to your personal data

As a person whose personal data we process, the applicable data protection legislation provides you with certain rights that you can exercise effectively in the cases provided by the legislation.

In short, your rights are:

Right of access. You have the right to ask us to confirm whether we are processing your personal data and, if so, to obtain that data and further information.

Right to rectification. If you find that your personal data that we process is incomplete or inaccurate, you may request its correction or completion.

Right to erasure (right to be forgotten). In certain circumstances - such as if your personal data has been unlawfully processed, you can request that we erase all personal data about you. In certain cases, this right is also linked to your right to withdraw the consent provided to us (if the processing of your personal data is based on consent) and there is no ground for us to continue processing your personal data.

Right to restriction of processing. In certain circumstances - such as if you doubt the accuracy of your personal data or have objected to our legitimate purpose for processing your personal data, you may request that we restrict the processing of your personal data, in which case active use of the data should cease, but without the data being permanently deleted/destroyed.

Right to data portability. Where we process your personal data on the ground of your consent or on a contractual groundand the processing of your personal data is carried out in an automated manner, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transfer it to another controller or to request that we transfer it to another controller.

Right to object. In certain circumstances - such as if you doubt our legitimate interest in processing your personal data, you could object to the processing of your personal data on grounds relating to your particular situation, to such processing where we are carrying out that activity on the grounds of legitimate interest or in the performance of a task carried out in the public interest.

Withdrawal of consent: in the event that we process personal data on the groundof your consent or explicit consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of processing based on consent, before it is withdrawn.

You can exercise these rights by submitting an application that meets the requirements of the Data Protection Act. More information on the content and conditions under which you can exercise the above rights can be found in the applicable data protection legislation. If necessary, you can also contact us for assistance.

To contact us, please use e-mail: contact@worktalent.com and the contact form in the worktalent.com Portal.

Data Protection Officer: Daniela Vasileva Grigorova-Mancheva, phone: +359878527750, e-mail: contact@worktalent.com, Sofia, 19, "Knyaz Aleksandar Dondukov – Korsakov” Blvd., floor 4.

In the event that you consider that we violate your rights in relation to the protection of your personal data, you have the right to file a complaint with the competent supervisory authority in the Republic of Bulgaria - the Commission for Personal Data Protection, or with the court.

Last update - 26 April 2024.