HORIZONS BULGARIA · PRIVACY

Privacy and Personal Data Protection Policy

This Policy explains how Horizons Bulgaria processes personal data in connection with recruitment, HR and consulting services, the horizons.bg website, The Ultimum HR tools, customer support, payments and related communications.

Last updated: 24 July 2026

1. Who is the data controller?

Horizons Bulgaria Ltd (Хорайзънс България ЕООД), registered with the Bulgarian Registry Agency under UIC 175011353 and VAT No. BG175011353, is the controller of personal data processed for the activities described in this Policy.

Registered and correspondence address
63 Tsanko Tserkovski Str.
1421 Sofia, Bulgaria
Managing Director
Katya Sotirova-Ivanova
Data protection requests
privacy@horizons.bg

2. When does this Policy apply?

This Policy applies when you:

  • visit or interact with horizons.bg and its language versions;
  • apply for a job, submit a CV or communicate with our recruitment consultants;
  • represent an employer or request recruitment, Employer of Record, HR, salary, consulting or related services;
  • use free or paid tools within The Ultimum HR, including CV, job description, job advertisement, salary benchmark, chat and related document tools;
  • make a payment, request an invoice, download a document or use a private sharing link;
  • contact us by form, email, telephone, chat, social network or another communication channel.

Where a specific tool requires additional information, a short privacy notice may be displayed at the point of collection. That notice supplements this Policy.

3. Personal data, purposes, legal bases and retention

We process only data reasonably necessary for the relevant purpose. The exact information depends on your relationship with Horizons Bulgaria and the service you select.

Context and data Purposes Legal basis Retention criteria
Website and technical data
IP address, device, browser, requested page, time, referring URL, security and error logs.
Delivering and securing the website, preventing misuse, diagnosing errors and producing aggregated service statistics. Legitimate interests in operating, securing and improving our digital services; consent where a non-essential cookie or similar technology requires it. For the period necessary for security, diagnostics and aggregated analysis, according to the applicable log and cookie settings.
Candidates and job applicants
Name, contact details, CV, photograph where provided, employment history, education, skills, salary expectations, preferred positions, interview and assessment information.
Responding to applications, matching candidates with roles, recruitment communication, interviews, assessment, career support and compliance with employment-intermediation obligations. Steps requested before a contract; performance of a contract; legitimate interests in recruitment; consent where required; legal obligation. For the recruitment process and, where a valid basis exists, for future suitable opportunities. Records are periodically reviewed and deleted or anonymised when no longer necessary, subject to legal claims and statutory obligations.
Employer representatives and clients
Name, role, company, business contact details, requests, correspondence, contractual and service information.
Preparing offers, providing recruitment and HR services, account management, communication, invoicing and protecting legal rights. Contract and pre-contractual steps; legitimate interests in business communication and service management; legal obligation. For the commercial relationship and applicable limitation, accounting and tax periods.
Forms, support and chat
Name, email, selected profile, messages, attachments and conversation metadata.
Answering enquiries, providing support, forwarding a conversation to the relevant team and sending a reply by email when the visitor is offline. Steps requested by you; legitimate interests in customer support; consent where the form expressly requests it. Active conversations are retained only as necessary to provide support. Important conversations forwarded to a department may be retained with the related request or service record.
Payments and invoices
Customer type, name or company, email, billing address, registration and VAT numbers, country, product, price, currency, order and payment status.
Creating a payment order, confirming payment, delivering the purchased result, issuing invoices, accounting, tax compliance, fraud prevention and handling complaints or refunds. Contract; legal obligations; legitimate interests in payment security and legal claims. For the statutory accounting and tax retention periods and any applicable limitation period.
Marketing preferences
Email, contact details, preferences and consent records.
Sending requested newsletters, service information or marketing communications and documenting your choice. Consent or, where permitted, legitimate interests and the applicable electronic-communications rules. Until consent is withdrawn or you object, plus the minimum record needed to respect and evidence your preference.
Public and professional sources
Professional information made public on company websites, professional networks, job platforms, registers and other reputable sources.
Identifying and approaching potentially suitable professionals, validating business information and providing recruitment services. Legitimate interests, balanced against the individual’s rights and reasonable expectations. Only while relevant and necessary for the recruitment or business purpose, with periodic review.

Required and optional data: mandatory fields are marked in the relevant form. If data necessary for a contract, payment, invoice or requested service is not provided, we may be unable to complete that request. Optional profile information can be left blank.

4. The Ultimum HR, AI-assisted tools and digital documents

Uploaded and generated content

Depending on the tool, you may provide a CV, job title, job description, professional history, education, skills, photograph, company information, logo, document text, salary criteria or chat content. We process that content to perform the function you requested, create an editable result, prepare a preview, complete a paid document and provide download or sharing access.

OpenAI API

Enabled functions may use the OpenAI API for tasks such as CV extraction, translation, drafting, text improvement and technology-assisted research. The instructions and content necessary for the requested operation may be sent to OpenAI. We do not publish our API key and do not use the consumer ChatGPT account of the visitor.

AI-generated or AI-assisted results may contain inaccuracies or unsuitable wording. They must be reviewed by a person before being used. Horizons Bulgaria does not use The Ultimum HR to make solely automated final decisions that produce legal or similarly significant effects, such as a final hiring or rejection decision.

Salary benchmark reports

Salary benchmark reports are Horizons Bulgaria research assisted by technology and current public sources. Results, tax assumptions, estimated net pay and employer cost remain indicative and should be confirmed by a qualified local payroll, tax or legal adviser before a binding decision is made.

Private links and browser storage

Where a tool offers a private sharing link, the link remains active only for the period stated in that tool, normally up to 30 days, and must be kept confidential by the user. Some unfinished drafts and remembered billing details may be stored locally in your browser on the device you use. You can remove them through the tool, browser storage controls or by clearing site data.

Windows video application

Where Ultimum Video Refresh is offered, camera processing is intended to take place on the user’s device. The application requires camera permission and may install or use a virtual-camera component. Separate application notices, licence terms and system requirements apply to the Windows installer.

5. Payments, VAT validation and service providers

Revolut Merchant

Revolut processes the checkout and payment method. Horizons Bulgaria receives the order identifiers, payment status and transaction information necessary for delivery, invoicing and support. We do not store the full card number or card security code.

VIES

For a business invoice, a VAT number may be submitted to the European Commission’s VIES service to validate its status.

Hosting, email and security

Hosting, backup, security and transactional-email providers may process limited technical, contact and message data under contractual and confidentiality obligations.

Analytics and cookies

Analytics, advertising or similar non-essential technologies are used only where enabled and subject to the choices presented by our cookie-consent mechanism. See our Cookie Policy.

6. Who may receive personal data?

Where necessary and supported by a legal basis, data may be disclosed to:

  • employer clients, where a candidate is considered for a suitable opportunity and disclosure is appropriate for the recruitment process;
  • candidates and authorised client representatives involved in the relevant recruitment or HR service;
  • IT, cloud, hosting, email, security, payment, accounting and professional advisers acting as processors or independent controllers under applicable terms;
  • OpenAI for the enabled AI-assisted operation requested by the user;
  • Revolut for payment processing and payment-related compliance;
  • competent authorities, courts, regulators and the Employment Agency where disclosure is required or permitted by law;
  • a prospective purchaser or successor in a legitimate corporate transaction, subject to appropriate confidentiality and legal safeguards.

Horizons Bulgaria does not sell personal data.

7. International transfers

Some technology providers may process data outside Bulgaria or the European Economic Area. Where the receiving country is not recognised as providing an adequate level of protection, we use an applicable transfer mechanism, such as the European Commission’s Standard Contractual Clauses, together with additional safeguards where required.

Information about a relevant transfer mechanism can be requested at privacy@horizons.bg, subject to the protection of confidential and security information.

8. Retention and deletion

We do not keep personal data indefinitely. The applicable period is determined by:

  • the duration of the requested service, recruitment project or client relationship;
  • the validity period communicated for a private link or digital result;
  • whether the person has validly agreed to future recruitment contact;
  • statutory accounting, tax, employment-intermediation and record-keeping obligations;
  • security needs and applicable limitation periods for legal claims;
  • a valid request for deletion, withdrawal of consent or objection.

At the end of the relevant period, data is deleted, securely destroyed or irreversibly anonymised unless a further legal basis requires its retention.

9. Security

We use organisational and technical measures appropriate to the nature and risk of the processing, including access controls, role-based administration, confidentiality obligations, secure connections, protected API credentials, backups, logging, software maintenance and incident-management procedures.

No internet or storage system can be guaranteed to be completely secure. Please use private sharing links carefully, do not place confidential data in unnecessary free-text fields and notify us promptly if you suspect unauthorised access.

10. Your data protection rights

Subject to the conditions and exceptions in applicable law, you may request:

Information and access

Confirmation whether we process your data and a copy of relevant personal data and information.

Rectification

Correction of inaccurate data and completion of incomplete data.

Erasure

Deletion where the data is no longer necessary or another applicable ground exists.

Restriction

Temporary restriction of processing in the circumstances provided by law.

Portability

Receipt of certain data in a structured, commonly used, machine-readable format.

Objection

Objection to processing based on legitimate interests and an unconditional right to object to direct marketing.

Withdrawal of consent

Withdrawal at any time, without affecting processing lawfully carried out before withdrawal.

Human intervention

Applicable safeguards regarding solely automated decisions that have legal or similarly significant effects.

To exercise a right, email privacy@horizons.bg. We may request proportionate information to verify identity and protect data from unauthorised disclosure. We normally respond within one month, subject to lawful extensions for complex or multiple requests.

11. Questions and complaints

Questions, requests and complaints concerning Horizons Bulgaria’s processing should be sent to:

You also have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria, or with another competent supervisory authority where applicable.

12. Children’s data

Our recruitment and HR services are generally intended for adults and persons legally able to seek employment or use the relevant business service. We do not knowingly invite children to purchase The Ultimum HR products. Where a specific recruitment activity lawfully involves a minor, appropriate information, legal basis and parental or guardian involvement will be arranged where required.

13. Changes to this Policy

We may update this Policy to reflect changes in services, technology, providers or law. The current version and update date will be published on this page. Where a change materially affects an existing processing activity, we will provide additional notice when required.

“`