"HR Labs" OOD Job Applicants Privacy Notice

We, "HR Labs" OOD, hereinafter referred to as "HR Labs", "we" or "us", are committed to protecting your privacy and your concern about it. Therefore, we have adopted this Job Applicants Privacy Notice (the “Notice”) which describes the privacy practices that apply to our collection, use, protection and storage of personal information submitted from applicants for employment with HR Labs or with the clients of the HR Labs, as well as what are your rights with regard to your personal information. We respect the privacy of your personal information and undertake not to use the data you provide for purposes other than the Company's recruitment goals and the implementation of employment mediation activities within the meaning of the Bulgarian Employment Promotion Act.

The processing of your personal information will always be performed in accordance with Regulation (EU) 2016/679 or General Data Protection Regulation (the “Regulation”) and the Bulgarian Personal Data Protection Act.

The Notice applies to job inquirers and job applicants.

1. Information about the Controller

   The Controller of personal data provided by you when applying for a job is “HR Labs” OOD, registered with the Commercial Register and Register of NPLE with UIC: 206968486, having its seat and business address at № 17A “Tsar Osvoboditel” blvd., 2nd floor, Sredets region, Sofia 1504, Bulgaria; and e-mail for contacts: [email protected].

   The Company is registered as a recruitment agency under the Employment Promotion Act with registration certificate №3357 / 13.07.2022, issued by the National Employment Agency.

2. Categories of Personal Data collected

   In order to participate in the recruitment process for а specific job position or for your application to be considered for any future position, we ask you to provide the personal information about yourself which you provide on voluntary basis and to the extent determined by you to HR Labs, by submitting your CV, cover letter, portfolio or other document upon your discretion. However, a certain minimum of personal information is necessary to complete an evaluation of your application. Examples of that type of personal information:

   • personal data allowing the identification and connection with the job applicant: name, city and country of residence, email address and telephone number, as well as username and profile in Skype, Linkedin and other communication and social platforms, in case you have voluntarily provided us with such information in the selection process;
   • personal data that allows the evaluation of the candidate’s skills and qualities with the criteria listed in the vacancy notices: educational and employment background, including information for previous employers, type and period of performance of the held position; main responsibilities; job qualifications; language skills and qualifications and etc.

   You may also decide to share other information that you consider important and relevant to the evaluation process, namely:

   • information about other skills, competences and qualifications;
   • references from your previous employers, teachers, tutors and etc.;
   • information about your interests, hobbies, activities and etc.

   In some cases job applicants may decide to share categories of personal data, which are “sensitive” under the meaning of applicable legislation, for example: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union or organization membership, organizations with religious, philosophical, political or trade union purposes; information regarding health and sex life of the job applicant. In other cases job applicants may decide to share data from their identity document (like number, expiry date) or personal identification number. As far as these data are not relevant to the evaluation process and are not necessary to HR Labs, we recommend that you do not include them in your CVs and other documents you share, applying for a particular or future position with us. In case that despite our recommendations you have provided us with such personal data, we believe that this has been done voluntarily, on your own initiative and with your consent, and we will store and process these data with due care and in compliance with all the requirements of the applicable legislation.

3. How we use your personal data?

   We respect the desire of the job applicants who have shared their CV, cover letter or other document containing personal data that we use the information provided to us precisely for the purpose for which it was provided. In this regard, we collect, use and process the information described above for the purposes provided in the Notice, for example:

   • to process and evaluate your application when making hiring decisions;
   • to provide your application to our clients – employers searching for employees;
   • to communicate with you and provide you with information of current and future career opportunities (if you have consented to this and to the receipt of such correspondence);
   • to manage and improve the hiring processes with HR Labs;
   • for the fulfillment of our legal obligations, including accountability obligations to the National Employment Agency in connection with HR Labs’ recruitment intermediation activity.

4. Categories of recipients of personal data

   Your personal data are processed for the purposes described above. We may disclose the personal data to the extent that we consider such disclosure to be necessary for the fulfillment of these purposes to the following recipients:

   • clients of HR Labs – employers looking for employees with whom HR Labs has concluded a contract for the provision of intermediary services;
   • subcontractors and suppliers who provide services such as equipment maintenance, software and hardware used to process personal data and to perform various services and technical support;
   • competent authorities, establishments and people who are authorized to require the provision of personal data and to whom we are obliged to provide personal data under the applicable legislation;
   • a potential seller or buyer in case when the Company, as a Controller of personal data, is being sold, or when it is buying, or is in the process of selling or buying all or a part of its business or assets.

5. How long we retain your personal data?

   We retain your personal data in accordance with the principle of limiting the period of retention of personal data, for which purposes we have approved a period for their retention of up to 6 (six) months, counted from the moment of completion of the selection procedure for the position for which you have applied. If you have expressed a desire for your application be considered in a selection for future vacant positions in HR Labs and/or clients of HR Labs, which positions, in our opinion, are suitable for you in view of your educational and professional qualifications and experience, we will retain your personal data for a period of up to 3 (three) years, counted from the moment of their provision, or until the prior withdrawal of your consent to such future selection. After you send your application, you can contact us at any time by email: [email protected] and declare that you no longer wish to participate in the selection conducted by HR Labs. If within the three-year retention period you have requested that we stop retaining your personal data, HR Labs will delete your retained personal data, insofar as this does not conflict with our legal and contractual retention obligations.

6. You have the following rights in line with the processing of your personal data:

   • Right to access your personal data: you have the right to inquire from us what type of information (if any) concerning you is are being processed, and, where that is the case, to provide you with a notice in an intelligible form containing your personal data that are being processed, as well as any available information about their source and a copy of the personal data, which are being processed;
   • Right to rectification of any factual inaccuracy or incompleteness regarding your personal data: if you find that personal data that we process about you is inaccurate or incomplete, you have the right to have us correct such personal data without undue delay;
   • Right to withdraw your consent for processing of personal data: you have the right to withdraw or decline your consent to us processing your personal data at any time, bearing in mind that this could prevent certain desired outcomes from occurring, such as considering your application and offering future suitable positions, for example. Please note that withdrawing your consent does not affect the lawfulness of the processing of your personal data before its withdrawal;
   • Right to erasure of personal data: You can request that we delete or remove your personal data in case it is no longer necessary for the purposes for which it was collected or is being processed. Please note that this request will be granted provided we have no legal basis and/or obligation to retain this data;
   • Right to restriction of processing: under certain circumstances: (i) you contest the accuracy of your personal data in the period for which we have to verify its accuracy; (ii) the processing of the data has no legitimate basis, yet you do not want their deletion, but instead you request the restriction of their processing; (iii) you need the personal data to establish, fulfill or defend legal claims, and we no longer need the personal data for the specified purpose of processing; (iv) you have lodged an objection to the processing of personal data, where the evaluation of whether our grounds for processing are lawful is pending;
   • Right to object to processing:if there is a legal basis for this, as you can object to the processing of your personal data and/or the receipt of messages from us;
   • Right to data portability:you can request that we provide you with the personal data you provided to us in an organized, widely used and machine-readable form;
   • Right to lodge a complaint with the Commission for Personal Data Protection (CPDP):if you believe that we are violating your rights or the applicable legal framework, please contact us to clarify the matter. In any case, you have the right to lodge a complaint with the Commission for Personal Data Protection through the means of correspondence set out in this Notice.

   We do not employ automated decision-making nor profiling when processing your personal data.

7. How do we ensure the security of your personal data?

   We guarantee the complete confidentiality of personal data. The personal information of any of the job applicants will not be published anywhere unless they have explicitly asked for it. As a Controller of personal data, we have implemented technical and organizational measures to ensure personal data processed remains secure. However, absolute security cannot be guaranteed, but we maintain security and incident response plans in the event of a physical or technical incident to handle this in a timely manner and limit any negative effect of such incident.

   Our site may contain links to our social network profiles or to other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and we bear no responsibility for them.

8. How to contact us if you have questions about your personal data?

   If you have any questions or concerns regarding this Privacy Notice, please write to us at: [email protected].

   If you are not satisfied with the way we responded to your question, request or complaint regarding protection of personal data, you have the right to lodge a complaint with the Commission for Personal Data Protection. You can contact the supervisory authority at:

   Email: [email protected]

   Tel.: 02/91-53-518

   Or address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

9. Your obligation in relation to the provided information

   As we undertake numerous obligations and implement a wide range of technical and organizational measures to ensure the confidentiality of your personal data, you are also required to provide us only with information which is honest, truthful, accurate and not misleading in any way and the sharing of which is not infringing on any rights of any third party.

10. Changes to this Notice

    This Notice was last updated on 13.07.2022. We may change it to reflect changes in the law or our privacy practices. We will keep this notice updated and encourage you to check the website regularly to stay informed. If we make changes that substantially change your rights regarding the protection of personal data, we will provide you with an additional message.