Privacy Policy
Last update: May 21st, 2018
This Privacy Policy ("Policy") describes how we process personal data with respect to:
• use of our websites www.questers.com and www.questersgroup.com ("Website");
• our recruitment processes, including for our own needs and as a recruitment services provider for others and including if you contact us via our Website, through other websites (Jobs.bg, LinkedIn.com, etc.) or offline;
• social or public events hosted or organised by us or with our support.
Personal data means any information relating to identified person or to a person who can be directly or indirectly identified. Please read this Policy carefully so that you understand how we collect and use your personal data. Please note, that we may have other privacy policies in place for other processes (such as for instance processing personal data of our employees).
1. Data Controller and Contact Details
1.1. The data controller under this Policy shall be "Questers Bulgaria EOOD, a company registered in Republic of Bulgaria with company number 175406553 and having its registered office at № 17 "Henrik Ibsen" street, 5-th floor, Sofia, Bulgaria ("Questers", "us", "we", "our").
1.2. We are registered as data controller with the Commission for personal data protection of Bulgaria under ID № 324876. We are also registered with the Bulgarian Ministry of Labour and Social Policy under № 1967/02.12.2015 for the provision of recruitment services for others for the Republic of Bulgaria.
1.3. If you have any questions about this Privacy Policy you may contact us by mail on our registered office address or by email at [email protected].
2. Personal Data We Collect and Use
2.1. We may process the following types of personal data:
• for recruitment purposes we may process your: names, address, contact details including phone number and email, CV and CV related info, such as for instance current position, education, professional experience and skills, job preferences and expectations, photo, references, interviews information, your public profiles in professional social networks (such as LinkedIn), business card and other relevant data;
• in your communication or interaction with us through any kind of contact (including telephone, email, forms on our Website, instant messengers, social media websites and profiles) we may receive and process only information you provide us, such as names, email, phone number, social network profile, CV, preferences, photos, addresses, etc. that you provide to us;
• when You access and use our Website we may collect and process information about your device (including, where available, your IP address, operating system, browser type, location) and how you use our Website. We may also receive cookies data, so please see our Cookie Policy for further details.
2.2. We may collect your personal data from:
• you, when you use our Website or communicate, or interact with us;
• from our partners, such as recruitment agencies, our current and ex-employees, when they make reference to you;
• from other third parties, such as for instance social media for your public profiles in professional social networks, references to you in recruitment campaigns or social events.
2.3. Sometimes we may ask you to provide us particular personal information for a specific purpose and provision of such information may be conditional in meeting that purpose. That may be the case for instance to register for an event, to submit to us your CV for a recruitment campaign, etc. In such cases, if you do not provide the necessary data, you will not be able to receive respective services/result.
2.4. Your responsibility:
• When you submit to us any data or materials, including personal information, you represent that you have the authority to do so and permit us to process such data as set out in this Policy and this will not violate any rights of third parties, including the right to privacy, the right to freedom, copyrights, related rights, intellectual property rights, etc.
• Although our policy is to process personal information only limited to the extent that is necessary in relation to the purposes as set out herein we encourage you not to submit to us unnecessary personal data (such as for instance photos of your family).
• When you provide us personal data or get in touch with us you represent and warrant that you are at least 18 years old. Our services and processes are not intended to persons below that age and we do not intentionally collect and process data of younger persons on regular basis.
• Please note that when you contact us in social media, such as Facebook or LinkedIn, our profiles may be public and your interaction or posting may appear to be public. Please note that we do not control and assume responsibility for the use of your social media profile and account.
• This Policy does not address and we are not responsible for the privacy, information and other practices of any third parties, including any third parties operating external website, app or service to which our Website may link (such as for instance LinkedIn, Facebook, our clients, etc.). We encourage you, if you choose to visit or use any of these third-party websites or services, to review their privacy policies that may be different from our Policy.
3. Purposes of Processing (How We Use Your Data)
We may use and process your personal data for the following particular purposes:
• for recruitment and selection purposes in current campaigns, including for our own needs and as a recruitment services provider to our clients and including if you contact us via our Website, through other websites (Jobs.bg, LinkedIn.com, etc.) or offline, inter alia to contact you, to make a preliminary assessment, to select suitable candidates, to conduct interviews with selected candidates, to make assessments and job offers, to introduce you to potential employers, etc.
• for recruitment purposes and job opportunities in future campaigns, when you agreed to such use or when we act in our capacity of recruitment services provider, to send you job alerts and information on open positions in future campaigns;
• for establishing compliance with or performance of obligations to clients of our Group with respect to selection process or recruitment campaigns, including for your introduction to them;
• for purposes of social or public events organised or hosted by us or with our support, including to invite you, to provide you relevant information and materials, to make public photos during the event, to introduce you on the event to other participants, to advertise and publicise the event in different medias;
• to send you marketing or promotional materials for our services, our business and clients, recruitment campaigns, public events, etc., when we have your consent.
• to conduct a poll or research when you agree to participate;
• to communicate with you, including when you contact us for respective purpose and to manage our social network profiles when you interact with them;
• to send administrative information to you, for example, information regarding our rules and changes to our terms and policies;
• for safety and security purposes, when you access our buildings and offices, or to verify accounts and activity, to detect and prevent harmful conduct, fraud or violations of our, or our partners', or public rights and interests;
• to comply with this Policy;
• for statistics and analysis to improve our services, procedures, policies and Website, including to prepare offers, market or trends information to potential or actual clients of our Group;
• to comply with or fulfil obligations arising from law, act of the authorities or of the court, including to address disputes and legal claims that may arise.
4. LEGAL BASIS FOR PROCESSING YOUR DATA
4.1. When we process your personal data we may do that on the basis that it's necessary for the conclusion or performance of a contract to which you are party. That will usually be the case when we process your data for recruitment and selection purposes in running campaigns or when we act as a recruitment services provider, or when you submit your data to us for particular open position.
4.2. To use your data and offer you job opportunities in future we will usually need your consent. We will need your consent also to send you marketing or promotional materials for our services, our business and clients, for public events, or for your participation in a research project. You will always have the right to withdraw your consent (if that's the basis for processing) as detailed below in this Policy.
4.3. We may also process your personal data on the basis of our legitimate interest or the legitimate interests of a third party, where such interest is not outweighed by your interests or fundamental rights and freedoms. Such will be the case when we process your data for the purposes of contacting your public profile in professional social networks based on your stated experience and job preferences, for safety and security purposes and to prevent violation of rights or other interests, for collection of due payments, for statistics and analysis to improve performance and services, to prepare and use market or trends information.
4.4. We may also process your information where that is necessary for compliance with our legal obligations, such as for instance for accounting purposes or to maintain records.
5. RECIPIENTS OF PERSONAL DATA
Your personal data may be disclosed in the following ways:
• to our clients that you may work with or provide services to if we enter into an employment agreement; or if we act as recruitment services provider - our clients that are looking for respective job candidates. The client will see your CV and we may also share other relevant data for you, such as references, interview information, etc.
• to our Group companies for the purposes described in this Policy, as "Group" companies are all companies that together with Questers are under common control;
• to our or our Group's companies vendors and service providers who support our business and in particular such as providing us technical infrastructure services, hosting or cloud services, Website maintenance, software and product licenses, email services, payment services, professional advisers, insurance companies and others;
• to third parties, including public authorities, if we are required to do so pursuant to applicable laws or legal, or court process, or in connection with an investigation of illegal activity or under lawful request from public or government or regulatory authorities; we may also share your data when we have a good-faith belief that this is necessary to prevent death or harm or financial loss, or in connection with an investigation of actual or suspected fraud or illegal activity, including violation of our or third party rights, such as for instance copyrights, intellectual property rights or privacy rights;
• to public, when you make certain interactions to our social network profiles, or attended to sponsored, hosted or organised public event;
• to third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business.
6. TRANSFER OF DATA TO THIRD COUNTRIES
6.1. In certain events for the purposes as detailed in this Policy we may transfer personal data to third countries outside the European Union, that may have different data protection laws than those of Bulgaria and of the EU. In particular, this may be the case in which we use a US based e-mail and storage service provider, or US based recruitment software. In such cases we will transfer your personal data to third country only on the basis of: (a) an European Commission decision on an adequate level of protection for that third country (art. 46 of the GDPR), including based on the Privacy Shield framework or other similar approved mechanism; or (b) appropriate safeguards as provided under art. 46 of the GDPR, including by utilizing the Standard Contractual Clauses in accordance with the Annex to the Decision of the European Commission of 05 February 2010 (available at the date of update of this Policy here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087) as amended or exchanged over time by the European Commission or other appropriate safeguards, including subject to specific permission of a competent supervisory authority; or (c) binding corporate rules approved by the supervisory authority (art. 47 of the GDPR).
6.2. In other events we may rely on and request your consent for particular transfer to third country.
7. RIGHT TO WITHDRAW YOUR CONSENT
When we process personal data based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal. You may exercise that right without additional costs to you by one of the following:
• at any time by sending us email to [email protected] with clear statement that you withdraw you consent; or
• by phone call to phone number +359 2 444 41 32 in standard local working days and hours (Mon-Fri/09,00-17,30); or
• by post a mail to our registered office at the attention of Head of recruitment;
In the event that you withdraw your consent for the processing of personal data we will, without undue delay and to the extent provided under applicable laws, erase the relevant data from our systems.
8. YOUR OTHER RIGHTS
8.1. You have the following rights with respect to your personal data and as provided under applicable laws:
• right to access - at any time you may request information about the personal data we have for you and the purposes of processing;
• right to rectification - you have the right to ask to rectify your data if they are inaccurate;
• right to erasure, "the right to be forgotten". You should keep in mind that this is not an absolute right and applies in accordance with applicable laws. For example, you have the right to request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected or otherwise processed, but only if there is no legal obligation upon us that requires further processing (e.g. some of your data to be further processed for accounting, control or compliance purposes). In any case, we will respect any lawful and legitimate request for erasure of your data;
• right to restriction of processing - this is your right to request that we limit the processing operations with your personal data as provided under applicable laws, such as for instance if you dispute the accuracy of your data and for the verification period;
• right to data portability - you may request that data provided directly by you and processed by automated means by us is transferred to you or to another controller. This right only being applicable where our processing of your data is based on your consent or on a contract with you;
• right to object. In particular the right to object includes that you may object at any time to processing of your personal data which is based on: a) the performance of a task carried out in the public interest or in the exercise of official authority vested to us; or b) pursuing our or third party's legitimate interests; or) the purposes of direct marketing.
8.2. In order to exercise your rights you may contact us at any time by sending us an email to [email protected]. We may need to verify your identity or to contact you with respect to your requests.
8.3. In the event that you are established in the European Union you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the EU of your habitual residence, place of work or place of the alleged infringement. For Bulgaria, the supervisory authority is the Commission for Personal Data Protection, having its website at www.cpdp.bg.
9. AUTOMATED DECISIONS
9.1. We may use software to search databases for relevant job candidates and suitable individuals. The software may be used to determine suitability for a specific role via targeted questions or criteria relating to the role and/or may identify individuals according to their characteristics. For instance the software may enable us to quickly identify individuals who have specific professional skills, e.g. Java Developer, Ruby Engineer, etc. or relevant professional experience.
9.2. Where we use software to assist us with our assessment of your suitability for a particular job role and you consider that any such assessment has been made wrongly or incorrectly, you may ask for an explanation. You may object to any decision, which significantly affects you, being taken solely by a computer, software or another automated process, if any.
10. STORAGE PERIOD
10.1. We will retain your personal information for as long as necessary for the respective purposes of the processing and to comply with our obligations under applicable laws.
10.2. In particular we may retain personal data:
• data for the purposes of concluding and executing a contract or for provision of services - generally for 5 years from the date of performance or termination of the contract;
• data for accounting and control purposes - in accordance with the applicable law, as for instance for 5 years from the end of the respective tax year;
• data for marketing purposes - until you withdraw your consent (if applicable) or until you object to processing or for 1 year as from our latest contact with you that provides you the option to opt-out.
• data, based on your consent, such as for instance your contacts, CV and preferences for future job opportunities - until you withdraw your consent (where applicable) or for 2 years as from our latest contact with you that provides you the option to opt-out.
• data we process for safety and security purposes may be retained for 1 year, unless a law provides for shorter period;
11. CHANGES IN THIS PRIVACY POLICY
We may change this Privacy Policy from time to time and you may see the last revision date of this Policy at the beginning of the document. Where the changes in the Policy affect processing of your data on the basis of your consent we will notify you of the new Policy and request your consent on it.