This Policy applies where we are acting as the data controller and we determine the purpose and means of the processing of the personal data you submit to us. We have also identified the areas where we have assigned the processing of your personal data to third parties so that you are aware.
1. What Data We Collect
As part of operating the Website, we collect your Personal Information. “Personal Information” means any information from which you can be personally identified, including your name, email address, home or business address and telephone number.
· you visit our Website,
· you request information or submit an enquiry; or
· when you register to receive our newsletter, which is distributed through our Email Marketing Program.
The general categories of Personal Data that we may collect, and process include, but are not limited to, the following:
· data about your use of our Website and services namely information about your visits to and use of this website (including your internet protocol (IP) address, geographical location, length of website visit, the time and date of website visit, page views and website navigation paths), (“Usage data”);
· information that you provide in order for us to be able to respond to your enquiry and/or to subscribe to the Courses (for additional information or otherwise) or your comments or complaints in relation to our Website and services (including your full name, email address and phone number), (“Correspondence Data”);
· information (including your full name, country of residence, address details, email address and phone number) and documents (including information regarding your education and work experience, your cover letter, your curriculum vitae (CV) and any other documents you wish to submit) which you provide to us for the purpose of completing and submitting an application form for a job vacancy on our Website (“Vacancy Data”);
· information that you provide to us for the purposes of subscribing to our email notifications and / or newsletters (“Notification Data”) and
· any other Personal Data that you choose to send to us in order for us to provide services.
You must not supply any other people’s Personal Data to us.
2. Processing of Personal Data
Personal Data submitted to us through our Website, will be used and processed for the following specified purposes:
· Usage Data:
· Legal Basis for Processing: our legitimate interests;
· Correspondence Data:
· Purpose of Processing: to enable us to respond to enquiries or complaints you may have about our Services and/or Website and/or job vacancies other information.
· Legal Basis for Processing: our legitimate interests;
· Vacancy Data:
· Purpose of Processing:
· To enable you to participate in our selection process and enable us to consider and analyze your application in respect of a role for which you have applied.
· To communicate with you in respect of the recruitment process.
· To consider and analyze your application in respect of other roles, whether current or future.
· During post – selection, your vacancy data may be further processed, anonymized and stored for statistical purposes.
· We may use analytical activities (via technological or other electronic means) to select appropriate candidates to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates may contain to
some extent automatic processing elements, however, any decision as to who we will engage to fill the job opening will be made by our recruitment team.
· Legal Basis for Processing: our legitimate interests;
· Notification Data:
· Purpose of Processing: in order to send you the relevant notifications and / or our email – newsletter / communications / updates relating to our business and jobs, which may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology you have specifically requested, if you have requested it (you can inform us at any time if you no longer require marketing communications).
· Legal Basis for Processing: your consent.
In addition to the specific purposes described above, we may process your Personal Data to the extent permissible by applicable law, in the good faith belief that such action is necessary for:
· compliance with a legal obligation or governmental agency request,
· the defense of our rights in legal or administrative proceedings,
· our protection against legal liability.
On occasion and like many other businesses, we may engage a third party to perform certain functions related to the processing of your Personal Data. Example of such functions, include the maintaining of a database of:
· CVs of users who opt to apply for a job vacancy through our Website;
· users who will receive email notifications and newsletters.
These are the details of the data processors in the above two cases (“Third-Party Processors”) we use:
– iCIMS, Inc.,101 Crawfords Corner Road, Suite 3-100, Holmdel, NJ 07733, USA
3. Disclosing Personal Data
We may disclose your Personal Data to any of:
· our employees, officers, suppliers, subcontractors;
· our Third-Party Processors who are our appointed data processors,
· affiliate companies and subsidiaries (including their employees, officers, suppliers and subcontractors);
insofar as is reasonably necessary for the purposes set out in this Policy.
We will disclose your Personal Data:
· to the extent that we are required to do so by law or by public and/or government authorities;
· in connection with any ongoing or prospective legal proceedings and to comply with legal process;
· in so far as it is reasonably necessary, for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to establish, exercise or defend our legal rights whether in court proceedings or in an administrative or out-of-court procedure (including providing information to others for the purposes of fraud prevention and reducing credit risk);
· to allow us to pursue available remedies or limit the damages which we may sustain.
4. International data transfers
As an international group of companies, we have offices and people around the world and more predominantly in the United States of America, Costa Rica, China, Vietnam, Republic of Cyprus, Bulgaria, Malta and Nigeria.
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use and process the information in accordance with this Policy.
Personal Data may be transferred outside the country in which it was collected and/ or processed, for legitimate business activities in accordance with applicable law. In addition, to the extent permissible by applicable law, the Company may store and/ or process Personal Data in facilities operated by Third Parties on behalf of the Company outside the country in which the Personal Data was collected and/ or processed. Countries outside the European Economic Area (“EEA”) do not always have strong data protection laws. Where the Company transfers the Personal Data from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as the EEA states, the Company takes measures to provide an appropriate level of data privacy protection. For example, the Company uses approved model contractual clauses, other measures designed to ensure that the recipients and/or processors of the Personal Data protect it.
5. Retaining and Deleting Personal Data
We shall not keep or process your Personal Data for longer than it is necessary for the processing purpose we have specified. Depending on the processing purpose, different timelines for retention of your Personal Data will be applicable, which we shall determine based on:
· the length of time needed to provide to you our Services,
· the reasonable length of time needed to
· respond to your request for information or to your complaint; or
· evaluate and assess your job application,
· whether your Personal Data is sensitive or not,
· whether you have consented to a longer retention period,
· Whether we are obliged, by law, contract or similar obligation to retain your Personal Data for a minimum specific time period.
Notwithstanding the other provisions of this paragraph, we will retain documents (including electronic documents) containing Personal Data:
· to the extent that we are required to do so by applicable law;
· if we are of the opinion that the documents may be relevant to any ongoing, imminent or prospective legal proceedings; and
· for the purpose of establishing, exercising or defending our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
At the end of the retention period, we will delete your Personal Data in a manner designed to ensure that it cannot be reconstructed or read. Particularly, we shall not be retaining Vacancy Data for a period longer than 2 years, if we find that the CV you have submitted is not relevant to any of the vacancies available at the time of its submission. If you request that you should not be able to access our Services (i.e. self-exclude), we will retain this information for a maximum of 7 years, from request, before deletion.
6. Security of Personal Data
The security of your Personal Data is very important to us. We will take reasonable, technical and organizational precautions to prevent the loss, unauthorized access, disclosure, destruction, misuse or alteration of your Personal Data. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect. All the Personal Information that you provide us is stored in a secure computing environment protected to prevent unauthorized access. We control access so that only people who need to access the Personal Information can. All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.
We may revise and update this Policy at any time. This revised Policy will be effective when posted/ published on the Website. Accordingly, if you disagree with and do not want to accept this Policy, as these have been revised, you must discontinue to use our Website.
8. Your Rights
You have several rights in relation to the Personal Data you have shared with us. These are in line with the applicable legislation and can be summarized as follows:
(a) Right to Access;
You have the right to request access your Personal Data that we hold including the right to be informed about the purpose of the processing and the recipients of your Personal Data. Provided the rights of others are not affected, we will supply to you a copy of your Personal Data that we hold but in doing so we may ask you to verify your identity.
(b) Right to Rectification;
You have the right to have any inaccurate Personal Data rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed.
(c) Right to Erasure;
Under some circumstances, you have the right to the erasure of your Personal Data without undue delay. Those circumstances can come about when:
· your Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed;
· you withdraw consent in circumstances where you had previously provided it;
· you object to the processing under certain rules of applicable data protection law;
· the processing is for direct marketing purposes;
· your Personal Data was unlawfully processed.
The right to erasure is not absolute and exclusions include circumstances where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; and/ or for the establishment, exercise or defense of legal claims.
(d) Right to Restrict Processing;
Under certain circumstances, you have the right to restrict the processing of your Personal Data. Examples of such circumstances include cases where you contest the accuracy of your Personal Data or our need to have access to your Personal Data for the declared processing purposes. If and when processing has been restricted on this basis, we may continue to store your Personal Data but we cannot otherwise process it:
(e) Right to Object to Processing;
If we have been processing your Personal Data on certain legal basis (such as legitimate interest) you have the right to object to such processing in certain circumstances. On the submission of such objection and unless we can demonstrate compelling legitimate grounds for the continuance of the processing which override your interests or if the processing is for the establishment, exercise or defense of legal claims, we shall seize the processing.
(f) Right to Data Portability;
If the processing is carried and by automated means AND the legal basis for our processing of your personal data is:
1. consent; or
2. performance of a contract to which you are party or
3. preparatory work at your request prior to entering into a contract;
you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, unless it would adversely affect the rights and freedoms of others.
(g) Right to Lodge a Complaint to a Supervisory Authority;
If you consider that our processing of your Personal Data infringes applicable data protection legislation, you have a legal right to lodge a complaint with the Bulgarian, Cyprus or other Supervisory Authority.
(h) Right to Withdraw Consent:
To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us via [email protected]
9. Third party websites
Our Website may include hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Sensitive Information
We ask you NOT to send or share with us any sensitive Personal Data (such as but not limited to your government-issued or financial account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic or biometric data, criminal background or trade union membership).
11. Our contact details
You can contact us by:
· post, using the addresses published on the Website;
· using our Request Information section on our Website;
· by telephone, on the contact number published on our Website; or
· by email, using the email address published on our Website.
Effective on December 1st. 2021