I. Contact details of the Controller and the Data Protection Officer:
Name: DNA Media АD
Address: Sofia, 11 Graf Ignatiev Str., 1st floor, apt. 3
II. What personal data do we process and how do we use it:
1. The Company processes the personal data of the following categories of individuals:
1.1. Individuals who have registered on the website;
1.2. Individuals who use the website without registering;
1.3. Individuals who made inquiries through various channels;
1.4. Individuals who have subscribed to our newsletter or signed up for events organized by the Company.
2. When you register on our website to use our services. To apply for a vacancy job position announced on our website, you must register as our user. When registering, you need to enter your name and surname, e-mail address, a photo and an answer to a question (optional). It is also possible that we process the following additional personal data: education, citizenship, residence, desired field of career development, and we will process such data only for statistical purposes. Once a user has created an account, they have the opportunity, at their discretion, to apply for one or more published job announcements by attaching an additional file with their resume (CV) to send to the company. The company will not have access to the personal data contained in the files attached by you, but will only forward the same to the employers of your choice.
3. When you use our contact form or other service on our website (for example, subscribing to a newsletter), we process personal data for the purpose for which you provide them to us, i.e. according to the specific function and your request. The required fields that we have set are the minimum information that we have considered necessary for us.
4. Your personal data received from third parties: If you "liked" our profile on a social network or you "followed" it, according to the practices of the respective networks, you will see messages, advertisements or materials published by us on our page. If you make an inquiry to us through the relevant page or, for example, comment on our post, we may use the functionality of the same network to answer you, and if you have asked us to contact you in another way, we will comply with your wishes in view of our legitimate interest in answering your inquiry.
5. We do not collect special categories of data - such as information about your race, political opinions, religion, health or sexual orientation, as well as any other personal data that fall into the special categories of personal data.
6. Data provided when participating in promotional campaigns.
III. What we use your personal data for:
We use your personal data collected through our website for a number of purposes, such as:
1. To introduce you to our cause aimed at improving the quality of life in our country;
2. To fulfill our obligations under the contract with you, giving you the opportunity after registration to apply for any of the vacant job positions announced on our website;
3. To provide you with the services for which you have subscribed, such as to send you advertising and other messages with your explicit consent;
4. For statistical purposes such as analyzing the operation of our website applications and to understand how visitors use them;
5. To respond to your inquiries and consider your complaints;
IV. On what basis do we process your personal data:
We use your personal data only when we have a legal basis for it. We determine the legal basis according to the purposes for which we have collected your personal data. In any case, the legal basis will be one of the following:
1. Consent: An example of this is when you provide your explicit consent to receive marketing communications from us. You can withdraw your consent at any time by following the instructions in the email containing the advertising messages.
2. Legitimate interests: When it is necessary to understand our users, to promote our services and optimize the work of our website for maximum efficiency. For example, we will rely on our legitimate interest when analyzing what content has been viewed on our website so that we understand how it is used, or to respond to your inquiry received through our contact form.
3. Contractual basis: When you register on our website, a contract for the provision of a service is concluded between the Company and you. Under this contract, we are obliged to maintain your account for the term of the contract and to provide you with the opportunity to use the services we have undertaken to provide.
4. Compliance with the law: In some cases, we may have a legal obligation to use or store your personal data.
V. Security of your personal data:
1. The company takes all necessary technical and organizational measures for data protection. We will also undertake the destruction of data that is no longer needed, except in cases where there is a legal obligation to process them for a longer period of time.
2. The Company has put in place security measures to prevent the accidental loss, use, alteration, disclosure or access to your personal data without permission. The Controller also provides access to your personal data only to those employees and partners who have a business need to have access to such data. They will process your personal data only on our instructions and they must keep it confidential.
VI. To whom do we share your personal data:
1. The Controller provides your personal data to certain categories of third parties in order to be able to offer you quality, fast and comprehensive service, such as:
1.1. Service providers - personal data processors. These can be hosting companies, IT service providers, system administration. We conclude contracts with them that guarantee the security of your data.
1.2. Other data controllers who provide us with relevant services - banks, auditors, lawyers, professional consultants and insurers, event organizers and others - when it is necessary for our legitimate interest to provide us with a particular service.
1.3. Public authorities that require us to declare processing activities.
1.4. Third parties to/with whom we sell, transfer or combine parts of our business or our assets - when and to the extent necessary in view of their legitimate interest to analyze our business and enter into the relevant transaction.
2. When you apply for a job position announcement, we will automatically forward your CV to the employer of your choice. We do not have access to the files attached by you, but only forward them by virtue of the contract concluded between you and us, as well as by virtue of the contract concluded between us and our partners-employers, in which case we are processing personal data for the client - employer.
3. The Company does not provide your personal data to third parties until it is sure that all technical and organizational measures have been taken to protect this data by exercising strict control over the implementation of this purpose. In this case, the Controller remains responsible for the confidentiality and security of your data.
4. International data transmission: Personal data are usually processed within the European Union or the European Economic Area; we do not intend to transfer personal data to other countries ("third countries"). If we transfer your personal data to a "third country", we guarantee that before such transfer the necessary level of data protection is ensured in the respective third country or with the recipient in that third country. This may be based on a decision of the European Commission on the adequate level of data protection in a particular third country as a whole. Alternatively, the transfer of data may be based on so-called "EU standard contractual clauses" agreed with the recipient or, if the recipients are in the US, on the basis of compliance with the terms of the privacy program between USA and EU.
VII. Terms of storage of your personal data:
1. Your personal data is stored for the time necessary to achieve the purposes for which it was collected. Once the purposes for which the personal data were collected have been achieved, we will destroy them immediately, unless there is an obligation to process them for a longer period of time.
2. Your personal data collected in connection with your registration on the website, respectively in connection with the contract concluded between us, will be processed until the moment when you state your desire to delete your account. In this case, we will destroy your personal data collected in this flow, unless there is an obligation that obliges us to process them for a longer period of time. In many cases, we will comply with the statute of limitations under applicable law, for example, for bringing certain claims, which is in our legitimate interest.
3. In some circumstances, we may anonymize your personal data for research, statistical or other purposes, in which case we may use this information for an unlimited period of time without further notice to you.
4. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have requested your permission to process your personal data and we have no other legal grounds to continue with this processing, and you withdraw your consent, we will delete your personal data within a reasonable time.
5. When we process your personal data on the basis of consent, for example for marketing purposes, they are processed and stored until we receive a request to withdraw the consent or the data to be deleted.
VIII. Your rights:
1. You have the following rights in connection with the collection, processing and storage of your personal data by the Company:
1.1. Right to information - the right at any time to request from us information about the personal data stored by the Company for you, as well as their origin, recipients or categories of recipients to whom they are transmitted, and the purpose of storage.
1.2. Right of access - the right to receive confirmation whether the Company processes your personal data, the right of access to them, as well as information about their processing.
1.3. Right of rectification - the right to request the Company to promptly rectify and/or supplement inaccurate personal data stored by the Company.
1.4. Right of erasure (the right to be forgotten) - the right to request the Company to erase (delete) or block your personal data, the processing of which does not meet the requirements of the Personal Data Protection Act and the General Data Protection Regulation. Part of the right to be forgotten is the obligation of the Company to notify the third parties to whom this data has been disclosed of any such erasure or blocking, except in cases where this is impossible and/or requires excessive effort.
1.5. Right to restrict the processing - the right to request from the Company to restrict the processing of your personal data when:
1.5.1. you dispute the accuracy of the data for the period in which the Company must verify their accuracy;
1.5.2. the processing of your personal data has no legal basis, but instead of the Company deleting them, you want their limited processing;
1.5.3. you have filed an objection to the processing of your personal data, pending verification of whether the grounds of the Company are legal.
1.6. Right to data portability - the right to receive your personal data, which you have provided to the Company and which relate to you, in a structured, popular format, suitable for machine reading, as well as to use this data for another controller at your discretion.
1.7. Right to objection - at any time you have the right to object to the processing of your personal data by the Company, if there is a legal basis for this. When the objection is justified, the right of the Company to process personal data is waived;
1.8. The right not to be subject to a decision based solely on automated processing, including profiling - the right to request human intervention by the Company in processing your data, the right to challenge the Company's decision and the right to state your point of view.
1.9. Right to withdraw consent - the right to withdraw at any time the consent given by you for the collection, processing and storage of your personal data by the Company, when personal data are processed on the basis of consent (for example for marketing purposes). Withdrawal of consent does not affect the lawfulness of storage and processing of personal data before the withdrawal, and will not affect the storage and processing of personal data by the Company in cases where the Company has another legal basis for storage and processing - a legal obligation to keep these data according to the provisions of the Bulgarian legislation and/or the law of the European Union, in fulfillment of a contract or in the presence of a legitimate interest.
1.10. Right to complain to a supervisory authority - In the event that you believe we are in breach of applicable law regarding the processing of your personal data, please contact us to clarify the matter. You have also the right to file a complaint to a supervisory body, which in the Republic of Bulgaria is the Commission for Personal Data Protection, with address: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd. You can find more about the activities of the Commission at https://www.cpdp.bg/.
2. If you wish to exercise your rights above or wish to learn more about the processing of your personal data, you should contact the Company by sending a request in free form to the above address or visit our office. Our colleagues will provide you with a form for exercising your rights regarding personal data, in which you should state which and to what extent of your rights you wish to exercise.
2.1. You will not pay a fee for access to your personal data (or for exercising any of the other rights). However, we may charge a reasonable fee, if your request is manifestly unfounded, repetitive, or excessive, or we will refuse to comply with your request in these circumstances.
2.2. We may need to ask you for specific information to help us verify your identity and guarantee your right of access to your personal data (or to exercise any of your other rights). This is a security measure that ensures that the personal data is not disclosed to a person who is not entitled to receive it. We may also contact you to request additional information regarding your request to expedite our response.
2.3. The Company undertakes to respond to each of your requests within 30 days of receipt of the request and without due fee. In the event of any difficulties in the timely execution of such requests, the deadline for execution may be extended by another 1 month, for which you will be notified within 1 month of receipt of your request.
We have the right to amend and update this Policy. We will publish such changes on our website www.bulgariawantsyou.com. If these amendments are significant, we will inform you further to your email or in other appropriate way to contact you.
This Policy is effective as of 14 July 2020.