This Privacy Policy is effective from 15.11.2023. 1. Introduction This Privacy policy („thePolicy“) governs the relations between You, the website Users, on one hand, and “TUG Personal” EOOD, entered in the Commercial Register to the Registry Agency under EIC: BG205023236, seated in the city of Sofia, Blvd. Maria Louisa 9-11, registered at the National Employment Agency to the Minister of Labourand Social Policy TUG Personal 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 about You, for what purposes, terms, and respectively what are Your rights. This Policy is fully compliant with the General DataProtection 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 Youdisagree 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 youracknowledgement of and agreement to our Privacy Policy. https://www.cpdp.bg/userfiles/file/ZZLD/ZZLD_02%2002%202023_Bg.pdf
2. Definitions For the purpose of this Statement the definitionsbelow ü Personal Data Controller – means a natural person or a legal entity who will determine the personal dataprocessing ü Company – is the Administrator of theplatform “TUG Personal” EOOD; ü Personal Data – any information, related to an identifiednatural person or a natural person, that could be identified(„You“, „You“, „Data Subject“or „User/s“); ü Processing – any operation or set of operations which isperformed on Personal Data or on sets of Personal Data; ü 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; ü Recipient – means any natural person or legal entity , public authority, agency or any otherstructure, to which the personal dataare disclosed, whether a third party or not; ü Personal data breach – means a breach of security leading to theaccidentalor 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 The Company shall process the Personal Data of the Website Users in the capacity ofan independent Controller. The employers should be considered as independent Personal Data Controller, who receive Personal Data about the Job applicants. The Controller shall collect and process Personal Data of the following categories of persons, namely: Job applicants, who applied with us; Applicants, who we provide or to whom we provide a job with some of our customers /employers/; Website Users https://www.tug-personal.com, as well as persons who apply through the platformsof our partners: jobs.bg, zaplata.bg, rabota.bg, etc.; It is possible that Personal 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: ü Full name; ü Date of birth; ü Email; ü Contact phone number; ü Data on the education graduated and any additionalqualifications, incl. language proficiency; ü Data on prior experience and employers; ü Data from work permits; ü Letters and digital messages that we receive fromYou in the communication between us; ü Video cameras footage for protection and security, when You visit our administrative facilities; ü Other data, collected when You use a contact form. We don`t 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 TUG Personal will processes 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: ü Concluding contracts with TUG Personal; ü Contract administration; ü Accessto our data base by employers; ü Financial relations; ü Application and request processing; ü Matching applicants with employers; ü Sending vacant position alerts; ü Management, evaluation and improvement of our activities;; ü Providing additional services like trainings, career consulting and career development; ü Valuation of the job applicant`s employability; ü Providing efficient communication; ü Providing security. 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 such information to us by yourself, whereas You elect and agree for it to be processed. 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 from the National Employment Agency that allows us to conclude with the applicants Job Placement Contracts that we must register in the information platform of the 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: TUG Personal involves third parties in order to support some of its contractual activities or to comply with 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 the IT 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. 7. Automated algorithms We do not use any automated decision-making tools. 8. What methods of TUG Personal 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 9. Data storage 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. TUG Personal 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: ü 5 years – for applicant data pursuant to Art. 41, par. 2 of the Ordinance on the terms and procedure for conducting job placement activities ü 3 years – for own recruitment as employer, pursuant to the Personal Data Protection Act; ü 10 years pursuant to the Accountancy Act for storage and processing of accounting data. 11. What are your rights and how can you exercise them? You have the legal right to: ü To unsubscribe from receiving commercial messages; ü To have access to the personal information that we store for you, in a convenient digital form; ü To require correction of the collected Personal Data, if they are incorrect; ü 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 ü To receive from TUG Personal information about our actions with regard to Your Personal Data, inclusive the purpose of collection and storage, storage period, collection method, etc.; ü To receive Your data and to transfer them to another Personal Data Controller; ü To contact us in case of questions, complaints or other problems, occurred with the processing of Your Personal Data; ü 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 TUG Personal as follows: Email: info@tug-personal.com Phone: +359 895 51 14 27/+359 896 87 65 66 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? Each independent Controller shall ensure the security of the personal data it processes. Information we share to protect our services and comply with the law We reserve the right to share your information when we have a good faith belief that the law requires it, when it is necessary to detect, prevent, and resolve fraud, unauthorized use of our services, violation of our terms of use, or other harmful illegal activity, and to protect our users. In this regard it is possible that Your Personal Datais shared with third parties – recipients under the following circumstancees: ü 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; ü aiming at an investigation of a possible crime like an identity theft; üwith 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.; ü with regard to a transformation (fusion, merger, separation and splitting), sale, purchase, business transformation, ü 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; ü 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 TUG Personal 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/. |
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case of anyquestions about this Statement.