POLICY FOR GENERAL DATA PROTECTION REGULATION OF HORIZONS BULGARIA LTD
February 14, 2019
Horizons Bulgaria Ltd. is a recruitment agency acting with a registration under Art. 5, p.1 of the Ordinance on the terms and conditions for performance of intermediary activity for employment (registration certificate for Bulgaria № 2118 / 27.09.2016, registration certificate for Other countries № 2119 / 27.09.2016 , certificate for performance of the activity as an enterprise which provides temporary job № 206 / 21.06.2017, issued by the Employment Agency);
Our mission is to provide business and job seekers with the best opportunities for working together and to help our clients to attract and retain the best professionals.
When providing our recruitment and career counselling services, and fulfilling our legal obligations to the Employment Agency, we collect, store and process personal data.
Horizons Bulgaria Ltd. guarantees the security of your personal data in accordance with Regulation (EU) 2016/679 regarding the protection of individuals with regards to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EU “).
In the current Privacy Policy (“Policy”) we provide information on how and why we collect personal data, what we do with it, who we share it with, how we protect it and what you may wish to do with regards to your personal information.
THIS POLICY APPLIES TO THE PERSONAL DATA THAT WE PROCESS IN CONNECTION WITH
- our website usage, responses for service requests
- delivery of services and products
- any other cases when we collect and use personal data.
In certain cases, the Policy may be supplemented by special privacy notices concerning specific services, tools, applications, websites, portals, marketing activities, sponsored social networking platforms, etc. provided and/or administered by us or on our behalf. We will notify you on a case-by-case basis when we process personal data on the basis of such special privacy notices.
PERSONAL DATA ADMINISTRATION
HORIZONS BULGARIA LTD, entered in the Commercial Register at the Registry Agency, with UIC 175011353, with headquarters and address of management in Sofia, Lozenetz district, 2 Midzhur Str. (“Horizons”) acts as an Administrator of your personal data in regard to its services.
For personal data issues, please contact us as follows:
• via e-mail to privacy@horizons.bg
• By letter to: Sofia – 1164, Lozenets district, Hristo Smirnenski Blvd 7
• over phone: 02 963 43 23
Processing of personal information from Horizons
IN THE COURSE OF THE ACTIVITIES CARRIED OUT BY HORIZONS, WE MAY COLLECT THE FOLLOWING PERSONAL INFORMATION
| Type of user | When we collect personal information | Purpose/ Activity | Type of information | Legal basis for information processing | Information processing Expiration date |
| Type of user When we collect personal information Purpose/ Activity Type of information Legal basis for information processing Expiration date Visitors to the websites https://www.horizons.bg, http://ceosearch.bg | In case of website visits and activities on: https://www.horizons.bg, http://ceosearch.bg | In order to be able to answer your questions and requests and to improve the management of our website. | Information that you give us voluntarily when you contact us through our website. | Undertaking steps upon your request before signing a contract and in order to provide you with a service. Legitimate interest in monitoring, analyzing and improving the management of our website, products and services. Legitimate interest in monitoring, analyzing and improving the management of our website, products and services. | 3 years |
| Jobseekers to whom Horizons provides mediation services for finding a job; | When applying for a job through platforms and websites: jobs.bg, zaplata.bg, rabota.bg, | To provide you with a mediation service – finding a job and hiring. | Name, email address, phone number; date of birth; nationality; work permit (if applicable); | Undertaking steps upon your request before signing a contract. Implementation of a mediation contract. | The data will be stored for a period of 6 months after the selection process is completed. In case we have the candidate`s consent – the data will be stored for a period of 3 years. |
| Candidates who have been delivered and recommended to us f by business partners in relation to positions with our clients. | social media: linkedin.com, Instagram.com, twitter.com, facebook.com and through the company’s website horizons.bgWhen signing a mediation contract between Horizons and a jobseeker. | Data for education and qualification, labour biography, language skills, recommendations; Preferences for career development and other data provided by the candidate on the basis of his/ her personal judgement. | Implementation of a statutory reporting obligation under the Ordinance on the terms and conditions for performance of intermediary activity for employment | ||
| Jobseekers, under the terms of a labour contract with Horizons as an enterprise providing temporary employment (Art. 107p of the Labor Code) | When signing a labour contract and sending for temporary employment to a user enterprise. | In order to perform our duties as an enterprise providing temporary employment. | Name, date of birth; personal identification number; nationality; work permit (if applicable); medical document for employability; criminal record (when applicable); bank account; | Undertaking steps upon your request before signing a contract. | 50 years |
| Name, email address, phone number; date of birth or a personal identification number; nationality; a work permit (if applicable); | Implementation of an employment contract for sending for temporary work to a user enterprise. | ||||
| Candidates for employment with Horizons Bulgaria | When applying for a job in Horizons Bulgaria. | In order to choose the most suitable candidates for our job opportunities. | Data on education and qualifications, labor biography, language skills, recommendations Other data provided upon the discretion of the applicant | Our legitimate interest in selecting the most suitable candidate. After selection, the personal data of the successful candidate will be processed with a view to concluding a contract. | The data will be stored for a period of 6 months after the selection process is completed. In case we have the candidate`s consent – the data will be stored for a period of 3 years. |
| Recipient of direct marketing. | Subscription to our newsletters or other types of marketing messages. | For sending you newsletters and other types of marketing messages as requested by you. | Your name and email address so we can send you the requested information. | Your consent to process your personal information. | Until the consent is withdrawn. You can withdraw your consent at any time. Withdrawal will not affect the processing of personal data that has already taken place. |
PERSONAL INFORMATION THAT WE COLLECT FROM THIRD PARTIES
- Information from logins on our internet supplier servers, such as information about your computer, your IP address, operating system, and search engine type (“Usage data”). This information is used by us to manage the systems and to analyse the use of our website. The legal basis for processing the information is our legitimate interest in monitoring, analysing and managing the content of our website in order to improve our products and services.
- We also collect personal information from our social network pages, including likes, shares, publications, and tweets. The legal basis for processing is our legitimate interest in monitoring and analysing our social networking pages and developing and improving the services we provide. Social networks have their own terms of use that you need to get acquainted with separately. You should keep in mind that publications on social networks may be related to certain consequences regarding the confidentiality of your Personal Data or the Personal Data of persons you share. You are entirely responsible for your publications and shared social networking information. We do not have any responsibility for your publications and shared information.
- Personal information, published in other publicly available information sources with high reputation such as the Commercial Register, linkedIn.com, facebook.com, job sites, and etc. The legal basis for processing the information is our legitimate interest in developing and improving the services we provide in the field of personnel selection at different levels and reaching the maximum number of potential candidates.
- We collect information via cookies or other similar technologies stored on your device for the way you use our website. Cookies contain information that is transmitted to the hard drive of your computer. They help us improve our website and provide you with improved and more customized services. Our Cookie Policy is posted here: https://www.horizons.bg/cookies-policy/
LINKED PLATFORMS
Our Websites may contain links to and from other websites and digital platforms of our affiliate networks, affiliates, and advertising companies. You should keep in mind that these websites are managed by third parties who apply their own privacy policies and we are not responsible for the way they process your personal data. You should be aware of the privacy policies of these third parties.
Google Analytics
In order to assess the usage of our sites and services, compose business reports, and provide other Internet related services, Horizons uses Google Analytics, a web analytics service provided by Google Inc. The Google Privacy Policy is available at: http://www.google.com/intl/None/policies/privacy/
By using the Horizons website, you agree that Google processes your data in the manner and for the purposes set out in the Google Privacy Policy. You may opt out of Google for processing your Display Advertising and/or Ad Personalization data by using the Google Ads Settings at http://www.google.com/settings/ads. For more information about Google Analytics: https://www.google.com/analytics/.
Processing the personal information, we collect
Horizons uses the information described above to perform the following activities:
- Providing business solutions for recruitment and representation of employees and mediation between employers and candidates;
- Notifying for vacant positions and entering into active contact with professionals;
- Management, analysis and improvement of our activity;
- Protection against fraud and other illegal activities;
- Other contractual and legal obligations;
- Compliance and enforcement of applicable legal requirements, sectoral standard and contractual obligations and internal rules.
In addition to the above described activities, Horizons may use the data provided by job applicants when:
- providing job opportunities and job propositions;
- providing additional services such as training, career counselling and career development services;
- analysing the professional suitability and relevance as a job candidate and the qualification of candidates for specific positions;
- analysing the data available to us, such as: analysis of our candidates` database, evaluation of individual results and opportunities, selection project duration, identification of missing skills, analysis of data channels, trends in recruitment and recruitment practices, and etc.
SHARING YOUR PERSONAL INFORMATION
Horizons does not disclose publicly or otherwise any personal data collected, except in the cases described in this Personal information Policy.
We may share your personal information as follows:
- To our clients
We share certain personal data in a minimum volume to our clients who are interested in offering suitable employment opportunities or who want to enter into contractual relations with our candidates.
- Service providers
In very rare cases, we share your personal information with service providers that Horizons uses to carry on its activity. These service providers are contractually obliged to keep the confidentiality and security of the personal data they receive and to use it only under our instructions.
- Public authorities
When we have an obligation to disclose or provide your personal data in order to fulfil any legal obligation or to implement and apply our terms under other contracts; or to preserve the rights, property and the safety of our company, our customers and others.
- Other cases
In case we sell our business or assets, we may disclose your personal information to the potential buyer of these activities or assets.
PERSONAL DATA TRANSMISION
In the event that the provision of our services involves the transfer of personal data to recipients outside the EEA, Horizons shall carry out such transfer in compliance with the CRDD requirements to ensure that appropriate measures are in place to ensure an adequate level of protection, for example: standard contractual clauses, etc.
Despite our commitment to protect your personal data, the transmission of data across the Internet is not entirely secure. Together with our service providers, we do our best to protect your personal data, but the decision to provide us with personal data is yours and it is taken at your own risk.
PERSONAL DATA SECURITY
Horizons maintains and implements appropriate administrative, technical and physical preventive measures for information security and protection of the processed personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Employees with access to personal data are trained to work with sensitive information and bound by contractual duty to treat the information as confidential.
Our data security protection procedures include measures related to encryption of all company dynamic and static data and introduction of a “fully forgotten” method into the company’s usable recruiting software.
Your rights
The law for protection of personal data s provides you with certain rights in relation to the processing of your personal data.
Right to information
You are entitled to information about how we collect and process your personal data, including who we are, how we use your personal information and what your rights are in relation to this. This information is provided in the current Privacy Policy.
Right to access your personal information
You have the right to access the personal data we store for you. We can confirm whether we process your information or not and we can give you access to your personal information.
Right to correct your data
If your personal data is inaccurate or incomplete, you have the right to request correction and update of this information by contacting us.
Right to delete your personal information
You have the right to request deletion or removal of your personal data when there is no reason to continue with the processing it. You may request to be “fully forgotten” when the data is no longer needed for the purposes for which it was originally collected or processed and when you have withdrawn your consent for processing it.
Right to Restrict Processing
You have the right to stop the processing of your personal data under certain circumstances, for example: when dispute with regards to data accuracy occurs- until the end of the dispute check; when you exercise the right to object to the processing.
Right to transmition of your personal data
When processing personal data with your consent or in connection with performance of a contract, you are entitled to receive your personal data in a commonly used, structured machine-readable format and to transfer them to a third party of your choice.
Right of objection
You have the right to ask us not to process your personal data for our legitimate interests, including for marketing purposes. We usually inform you (before we collect your personal data) if we intend to use them for such purposes or if we intend to disclose your personal data to any third party for such purposes. You may exercise your right to object to such processing by indicating your choice of designated locations in the forms we use to collect your personal data. You may also exercise your right at any time to contact us at privacy@horizons.com
When processing your personal data on the basis of your consent, you have the right to withdraw your consent at any time.
You can find additional information about how to defend your privacy rights to Personal Data Protection Commission at https://www.cpdp.bg/
If you have any questions or complaints
For additional information regarding the personal data we process or in case of complaints about this, you can contact us in the following ways:
- You can email us at: privacy@horizons.com
- By letter to: Sofia – 1164, Lozenets district, Hristo Smirnenski Blvd 7;
- By phone on phone number: 02 396 43 23
We will try to answer your questions as soon as possible.
You also have the right to complain to the Personal Data Protection Commission, additional information can be found here https://www.cpdp.bg/.
CHANGES OF THE PRIVACY POLICY
This Privacy Policy is subject to periodic changes and updates to reflect any changes in our privacy practices.
We will notify you about any changes to the Privacy Policy in an appropriate manner, with a visible post on our website, via email or other preferred communication channel.