Declaration on the processing of personal data of job applicants

"Kastamonu Bulgaria" AD undertakes to protect the confidentiality and personal nature of the information submited to the company. Our activities are held in compliance with The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ( "General Regulation on Data Protection") and the Bulgarian legislation on the protection of personal data. Please read this Privacy Notice to find out what information we collect about job applicants, how we use, share and protect it, what your rights are in relation to the protection of personal data and other useful information.

1. Controller of personal data

This Declaration for the processing of personal data refers to "Kastamonu Bulgaria" AD - entity registered in The Commercial register at The Registry Agency with UIC 123006579, having seat and registered address in the village of Gorno Sahrane, Municipality of Pavel Banya, region Stara Zagora (hereinafter referred to as "Kastamonu Bulgaria", "the Company" or "we"), which is The Controller of personal data.

2. Categories of data processed in the course of application

In connection with your application for employment, we may collect and process the following categories of personal data:

Personal identification data (three names, date of birth, current address);
Contact data (email address, postal address, telephone number);
Information related to your education, skills and professional experience (such as name of educational institution, period of study, year of graduation and educational qualification degree and certificates, professional qualification, participation in trainings and courses, data on foreign language proficiency, professional experience, presence/absence of legal capacity to perform certain activities, recommendations provided by you from current and previous employers or colleagues, etc.);
Information regarding your criminal conviction status, only when the verification of the said is imposed by a legal rule;
Other information contained in your application that you consider relevant and that you have indicated in your resume, cover letter and/or shared during interviews (such as job preferences, willingness to relocate, current salary, expected salary, honors or membership of professional bodies).

Special categories of personal data

Processing of personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs, membership to trade unions, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data related to the state of health or sex life and sexual orientation of a natural person, within the recruitment process is not necessary for us and we do not aim to receive this type of personal data from you. In this sense, please do not include special categories of personal data in the documents you submit with your application. In the event that you provide us with such information, you give your consent that we may use it in accordance with the applicable law and this Privacy Policy.

3. Ways of collecting personal data for recruitment purposes

We may receive your personal data in the following ways:

by submitting your application in paper format and in accompanying written documents, including a curriculum vitae with attached documents (e.g. diplomas, certificates, motivation letters, recommendations from employers and colleagues), as well as documents from external sources (e.g. judicial and other institutions in fulfillment of regulatory requirements);
by conducting an oral interview;
by providing personal data through the Jobs.bg platform;
by providing personal data to our e-mail;
by providing personal data through third parties - companies, recruitment intermediaries (if such are involved in the process)

4. Purposes of collecting personal data

The Company may use your personal data for any or all of the following purposes:

Pre-selection of job candidates;
Making contact with you to obtain additional information or to schedule an interview;
Sending an offer to you, in case you are evaluated as a suitable job candidate;
Storing your personal data for future vacancies or other employment opportunities, in case you have provided consent for this.

5. Legal grounds for processing personal data

5.1. Legitimate interest - We rely on legitimate interest as a legal basis for processing your personal data when we conduct a recruitment campaign for our own purposes and you apply for a specific position. In these cases, our legitimate interest relates to our intention to find suitable new employees to join our team, as well as to secure employment for you in the event that you meet the requirements for the position.

5.2. With your consent - In the event that you are not appointed to work at "Kastamonu Bulgaria" AD for the position you are applying for, with your consent, we can continue to process the personal data provided by you in order to be used for participation in selection for other vacant positions and for making contact with you at the discretion of "Kastamonu Bulgaria" AD.

6. Obligation to provide personal data

The provision of personal data is voluntary but necessary for the purposes of the recruitment process. You are not obliged by current legislation or by contract to provide your personal data to "Kastamonu Bulgaria" AD during the recruitment process. However, in the event that you do not provide us with the relevant information, we may be unable to consider or progress your application.

7. Sharing of personal data with third parties

Employees in the "Human Resources" Department, as well as heads of departments and sub-departments who participate in the examination of job applications, have full access to the personal data of job applicants collected by the company.

Outside of this access, we may share personal data with trusted third parties who assist us in carrying out the business of the company and provide us with timely and quality services. These third parties are legally bound to adequately protect the data we entrust to them. We may engage some or all of the following categories of third parties:

Kastamonu Entegre, when necessary to evaluate your application and only by virtue of a valid bilateral agreement between the companies for the processing of personal data;
Persons who facilitate the administration of our business or support our infrastructure or services (such as providers of telecommunications services, postal or transport services, storage and archiving services, maintenance or destruction services of data carriers, cloud software services);
Our professional consultants, including lawyers;
Bodies, institutions and persons to whom the administrator is obliged to provide personal data under the current legislation (such as The National Revenue Agency, The National Insurance Institute, The Labor Inspection, The Commission for the Protection of Personal Data, etc.)

8. Outside Bulgaria Processing of the personal data provided by the candidates

As a rule, "Kastamonu Bulgaria" strives not to send personal data of applicants outside the territory of The European Union (EU) and The European Economic Area (EEA). In certain cases, however, it is necessary to send specific data to persons outside the EU/EEA - Kastamonu Entegre Turkey (e.g. to consult the candidate's qualities and their compliance with the holding company's hiring policy), subject to the requirements of the applicable legislation and described in this Declaration.

In the event that the personal data of an applicant needs to be sent by Kastamonu Bulgaria AD to a country outside the EU or EEA, this will be done in compliance with this Declaration and in the presence of any of the following conditions:

When there is a decision of The Commission for Personal Data Protection or the European Commission, according to which the relevant country provides an adequate level of personal data protection;
When an agreement has been concluded with the organization to which personal data is sent, containing the standard data protection clauses approved by The European Commission.

9. Period of storage of personal data

The storage period for the personal data that we have received from you in the course of the relevant recruitment campaign is up to 6 (six) months. The terms start to run after the cancellation of the job advertisement or after the submission of documents, in the case of application undertaken by individuals of their own volition.

"Kastamonu Bulgaria" AD uses technology for safe maintenance and storage, updating, deletion, destruction, etc., of the personal data of job applicants for the entire storage period. For maximum security during data processing, transfer and storage, we may also use additional protection mechanisms such as encryption, pseudonymization, etc.

Your data can also be anonymized. Anonymization is an alternative to data deletion. Upon anonymization, all personally identifiable elements (elements that allow you to be identified) are irreversibly deleted. There is no legal obligation to delete anonymized data, as they do not constitute personal data within the meaning of the Regulation.

10. Your rights under data protection legislation

Your rights in relation to the protection of personal data are as follows:

Right of access – you have the right to obtain confirmation as to whether your personal data is being processed and, where this is the case, to obtain access to the data and detailed information about this processing;
Right to rectification – the right to modify or supplement inaccurate personal data relating to you;
Right to erasure ("the right to be forgotten") - the right to request the deletion of your personal data if there are no longer legal grounds for their retention;
Right to restriction of processing – right to request a processing limit if you dispute its accuracy, prefer to limit the processing of the data instead of asking us to delete it, or wish to keep it for you for the purposes of establishing, exercising or defending legal claims claims;
Right to data portability – the right to receive personal data relating to you in a structured, commonly used and machine-readable format;
Right to object – the right to object to the processing of personal data concerning you if there is no longer a reason for its use, in which case the controller should no longer process the data unless it proves that there are compelling legal grounds for processing that takes precedence over the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims;
The right to withdraw your consent to the processing at any time without affecting the lawfulness of the data processing prior to the withdrawal.
Right to complain - If you think we are violating Bulgarian or European legislation, please contact us to clarify the matter! However, in any case, you have the right to file a complaint before the regulatory authorities within the EU and The Republic of Bulgaria.

In case you want to exercise any of the rights mentioned above, as well as if you have any concerns regarding the way we process your personal data, you can contact us at:

Gorno Sahrane village, Municipality of Pavel Banya, 24 Shipchenska Epopeya St., or at the following e-mail address: hrbulgaria@keas.bg.

Applications for the exercise of rights are submitted in person or by a person explicitly authorized by you, through a notarized power of attorney. In the event that the application is submitted by post or in writing, without verification of an identity document by a representative of Kastamonu Bulgaria AD, the application should be accompanied by a notarized signature. An application can also be submitted electronically, according to the procedure for creating and submitting an electronic document, provided for in the current legislation. The application should contain: a) name, address, uniform civil number or personal number of a foreigner or other similar identifier, or other identification data of the natural person; b) description of the request; c) preferred form of communication and actions under Art. 15-22 of Regulation (EU) 2016/679; d) signature, date of submission of the application and address for correspondence; e) upon submission of an application by an authorized person, the corresponding power of attorney shall be attached to the application.

In the event that you wish to contact the regulatory authority responsible for the protection of personal data in The Republic of Bulgaria, you can contact The Commission for the Protection of Personal Data at the address:

Sofia 1592, Blvd. “Prof. Tsvetan Lazarov" 2

Phone number: + 359 (2) 91-53-519

Email: kzld@cpdp.bg

Website: www.cpdp.bg

In order to apply the most up-to-date protection measures and in order to comply with the current legislation, we will update this Policy in a timely manner. We invite you to regularly review the current version of this Privacy Policy, to be constantly informed.

This Privacy Policy for recruitment was last updated on 03/16/2023.