PRIVACY POLICY

Types of personal information we collect:

  • Information provided by you: This includes information you have shared in a registration form or a message sent by you.
  • Examples of data: This can include personal information such as your email, name, and phone number.

When visiting our website, you share:

  • Logs and history: This includes history and logs, as well as the time, date, and address of the web pages you visited.
  • Activity data: This includes the addresses of similar web pages and the searches you perform within the site.
  • Technical data: Technical information regarding your internet browser and your computer is also collected.

Legal Compliance: Marketing Solutions® processes your personal data in accordance with the rules of Bulgarian and European legislation regarding the protection of personal data.

Appendix

 General Personal Data Protection Policy of “MARKETING SOLUTIONS®” ltd

Types of personal information we collect:

  • Information provided by you: This includes information you have shared in a registration form or a message sent by you.
  • Examples of data: This can include personal information such as your email, name, and phone number.

When visiting our website, you share:

  • Logs and history: This includes history and logs, as well as the time, date, and address of the web pages you visited.
  • Activity data: This includes the addresses of similar web pages and the searches you perform within the site.
  • Technical data: Technical information regarding your internet browser and your computer is also collected.

Legal Compliance: Marketing Solutions processes your personal data in accordance with the rules of Bulgarian and European legislation regarding the protection of personal data.

Applicable from: May 2018.

  1. Introduction

This General Policy explains how we collect and process your data in our capacity as a Controller.

Your Responsibilities:

  • Familiarize yourself with the General Policy.
  • If you are in a contractual relationship with us, please check the associated terms and/or policies: they may contain additional details.
  • Note additional information and terms introduced at different stages of interaction.
  • If you provide us with personal information about others, we will use it only for the specific purpose for which it was provided. You must have a legal basis for providing third-party data and inform them how we will process it.
  • By providing data, you declare that you are over 18 years of age.
  1. Who We Are and How to Find Us
  • Marketing Solutions® Ltd. is the Controller of your personal data. Our main activity is in the field of Employment/Job Placement. Due to the specific nature of this business, there is a separate “Privacy Policy – Job Mediation and Recruitment”.

As this activity is specific, we have developed the following separate policies for it:

  • PERSONAL DATA PROTECTION POLICY – EMPLOYMENT AGENCY AND STAFF RECRUITMENT
  • Please, familiarize yourself with them if you use our employment services
  • If you have any questions about any of our policies or about personal data, please contact us.
  • Contact Address: Sofia, Reduta District, 46 Petar Bogdan St., Ground Floor. Email: market@marketing-bg.net.
  1. What Data We Process, for What Purpose, and on What Basis?

3.1 Website Visitors/Users (www.marketing-bg.net)

  • A) Automatically Collected Information: You can access the site without entering data, but information such as Cookies and Google Analytics is processed automatically.
  • B) Social Plug-ins: Use of Facebook, Twitter, LinkedIn, etc., is optional. These are links to third-party sites that collect data according to their own policies. We are not responsible for them, but in order to keep you informed and aware of your rights, we recommend that you familiarize yourself with them. We have placed these plugins to make our website more functional for visitors and to promote our activities and services if you voluntarily share our content on the respective sites. We consider this to be in our legitimate interest. More information about the social plugins used can be found here.
  • C) Links to Other Sites: Our website may link to other websites. If you follow these links, please review their specific privacy policies.
  • D) Personal data Provided via the Website: When using contact forms, we process personal data (e.g., minimum required fields) to respond to your request based on legitimate interest or pre-contractual/contractual grounds. The mandatory fields we have set (e.g in the contact form) are the minimum information we have determined we need. Please do not provide personal information about yourself that is not necessary for the purpose of the question.

Sometimes we process your data on a so-called pre-contractual basis. We apply this basis in all cases where you request to enter into a contract with us and we process your data necessary for this purpose. In other cases  there may be a contract between us and the processing of your personal data via the website may be related to the performance of our contract obligation. If you are applying for a job  with us, please refer to section 3.9 below.

  • E) Sensitive Data: We do not collect sensitive data (race, politics, religion, health, etc.). Please do not provide such information.
  • F) Combining Information: We may combine website data with info from other channels (email, phone) or public/third-party sources (Commercial Register, partners) for the same informed purposes. When we combine this information, we do not use it for any purpose other than those we have informed you about.

3.2 If you are visitor to our office

We may ask for your name, organization, and visit time to control access and security based on our legitimate interest. We will use this information in view of our legitimate interest in controlling access to our office and security, as well as to report and control internally the activities of our employees with whom you meet.

3.3 If you participate in our trainings, company presentation or other events:

  • We collect data necessary for participation and may ask for your preferences.
  • Events may be filmed or photographed for advertising purposes. You may inform us in advance if you do not wish for your image to be published.
  • We may contact you about future events; you have the right to object to this at any time.

Privacy Policy Sections

3.5. If you “follow” us on social networks.

  • If you have “liked” our profile on a social network or “follow” it, in accordance with 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 publication, we may use the functionalities of that same network to respond to you.
  • If you have requested that we contact you in another way (for example, by giving us your phone number), we will comply with your request in view of our legitimate interest in responding to your inquiry.

3.6. If you are a participant in our training:

  • We will collect the necessary information to register you.
  • We will process information regarding your participation, performance, and exam (if one is conducted).
  • We will also retain basic information about you to contact you occasionally and send you information about other similar trainings of ours.
  • We may also ask you for feedback on how you evaluate our training.
  • You always have the right to object to this way of using your data, as described below in relation to your rights.

3.7. If you are our business contact:

  • This means that you represent an organization—our partner, client, or supplier—or you are its employee.
  • To maintain our business relationship with the organization, we will often need information about you, such as: your names, phone, email, Skype contact, business card, and information about your position in the respective organization.
  • We will also process the following information: written/electronic or other correspondence with you.
  • Data contained in documentation regarding our relationship with the organization, such as your signatures, descriptions of your behavior, your statements, etc.
  • Any other information that is necessary for us in connection with the business relationship with the organization.

3.8. If you are our potential business contact:

  • This means that you represent an organization—our potential partner, client, or supplier—or you are its employee.
  • We may have your information from a professional public register, from a mutual business contact who recommended you, or you may have given us your business card or contact details at an event or meeting.
  • In these cases, we will make an assessment of the purpose and the basis on which we could use your contact data.
  • We will take into account the context in which this occurred, as well as your reasonable expectations regarding the use of personal data by us.
  • If we determine that there is a legitimate interest for us to contact you to request an offer, propose a partnership, or offer you our product or service, you will always have the right to object to such use of your data, as described below in relation to your rights.
  • In some cases, we may need to request your consent, and you will always be able to refuse to give it.

3.9. If you apply for a job with us:

  • This means that you have expressed a desire to become our employee by entering into an employment contract with us.
  • This can happen in two cases: (first) when you apply for a specific position announced by us and accordingly send us your CV and/or cover letter, or (second) when you send us your CV and/or cover letter without a specific announcement so that we may contact you if a suitable vacant position becomes available.
  • In order to take steps to review your application, we will examine the information you have sent.
  • If we definitively determine that you are unsuitable, we will delete your personal data within a period of up to 1 (one) week from making our decision, but no later than 2 (two) months from the deadline for selection for the open position.
  • If you apply for a specific position, but for some reason we cannot invite you to an interview or hire you for it and we wish to keep your information for the future (for other positions suitable for you), we will contact you to request your consent for this.
  • If you have sent your CV, but you do not apply for a specific position, we will assume that you have an interest in our organization as a whole. Therefore, if we so decide, we will retain your information to offer you work in the future based on our legitimate interest to select and hire employees who have shown interest in our organization. In this case, we will keep the information about you for the period for which you yourself have expressed a desire, and if you have not specified one—for a period of up to 3 (three) years.
  • During your application period, we will also collect additional information to assess whether we wish to enter into a contract with you, for example, information regarding your interview, your tests, and references you have provided.
  • When we determine that you are not suitable, we will delete the information about you.
  • Please do not provide us with information that is not necessary for your application with us.

3.10. For what other purposes may we use your personal data?

Below we have described the most typical purposes for processing personal data, but you should also keep in mind the following purposes:

  • For the administration of our activities, including reporting and analysis within the company itself—our legitimate interest.
  • Prevention of fraud and other illegal and criminal activities—our legitimate interest.
  • For the establishment and protection of legal claims—our legitimate interest.
  • For the fulfillment of our obligations under a contract to which you are not a party—our legitimate interest.
  • For analyzing the effectiveness of our services and activities and improving them—our legitimate interest.
  • For the fulfillment of our obligations under a contract to which you are a party.
  • For the fulfillment of our obligations applicable by law, for example, accounting, tax, and other obligations.

3.11. On what legal basis do we process your data?

  • 3.11.1. Our legal obligation – These are the cases in which the processing of your personal data is necessary for compliance with our legal obligation.
  • 3.11.2. Our legitimate interest – When we define our legal basis as “legitimate interest,” we first assess what it is and whether the processing of your data is necessary to achieve it. We also assess whether your interests, fundamental rights, and freedoms do not take precedence over it. Regardless of our assessment, you always have the right to object to processing based on legitimate interests, as described below in point 9.1.4.
  • 3.11.3. Pre-contractual or contractual basis – When we must take necessary steps, at your request, to enter into a contract between us or to fulfill a contract already concluded between us. In these cases, we will take care to process only the information necessary for the purpose.
  • 3.11.4. Your consent – This is a freely given, specific, informed, and unambiguous indication of your will, by means of a statement or a clear affirmative action, which expresses consent to the processing of your personal data for a specific purpose. If we need to process your “sensitive data” based on your consent, it must also be explicitly given. In point 9.1.7, you will find out how you can withdraw your consent at any time. Keep in mind that consent is a legal basis different from those described above; for example, signing a contract between us is not equivalent to giving consent.

If you have concerns or hesitations about what exactly the applicable basis is for a specific purpose of processing your data, you can always turn to us.

CAN YOU CHOOSE NOT TO PROVIDE YOUR PERSONAL DATA?

  • You are obliged to provide your personal data if there is a contractual or legal obligation to do so.
  • If you do not provide this data upon request in such cases, we may be unable to enter into or perform the contract, or achieve other objectives.
  • We will notify you in all such instances.
  1. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may need to share your personal data with the following parties:

  • Specific Employers: For a position you are applying for and are qualified for—based on our legitimate interest to administer and report our activities.
  • Service Providers: Data processors such as hosting companies, IT service providers, system administrators, couriers, and mobile operators. We sign contracts with them to guarantee your data security.
  • Other Data Controllers: Banks, auditors, lawyers, professional consultants, insurers, event organizers, and others—when necessary for our legitimate interest in receiving their services.
  • Public Authorities: Those that require us to declare processing activities.
  1. INTERNATIONAL DATA TRANSFER
  • Your personal data is usually processed within the European Union or the European Economic Area; in rare cases, it is transferred to “third countries”.
  • If transfer to another country is necessary, we ensure a required level of data protection is provided in that country or by the recipient.
  • This may be based on a European Commission adequacy decision , “Standard Contractual Clauses (SCC)” , or the EU-US Privacy Shield (where applicable). You can read more on www.privacyshield.gov/list.
  • Additional information regarding these safeguards is available upon request.
  1. INFORMATION SECURITY
  • We have implemented security measures to prevent accidental loss, unauthorized use, alteration, disclosure, or access to your data.
  • Access is restricted to employees and partners with a specific business need.
  1. DATA RETENTION PERIOD
  • We keep your data only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, tax, or reporting requirements.
  • Retention periods are determined by the volume, nature, sensitivity, risk of harm, and processing purposes of the data.
  • By law, basic information about clients (contacts, identity, financial/transaction data) must be kept for five years plus the current year for tax purposes after the relationship ends.
  • We also observe statutory limitation periods for legal claims.
  • Data may be anonymized for research or statistical purposes, in which case it may be used indefinitely.
  1. YOUR RIGHTS
  • Under certain circumstances, the law grants you the right to:
    • Access: Request a copy of the personal information we hold about you to verify lawful processing.
    • Correction: Correct or update incomplete or inaccurate information.
    • Erasure: Request the deletion of personal information when there is no good reason for continued processing or if you have exercised your right to object.
    • Objection: Object to processing based on legitimate interests or for direct marketing and profiling.
    • Restriction: Ask us to suspend processing, for example, to establish the data’s accuracy.
    • Transfer: Request the transfer of your information to another party (data portability).
    • Withdraw Consent: Withdraw consent at any time for data processed on that basis.

You can read more for these rights in the site of the Commission of Personal Data Protection

9.2 Exercising Your Rights

  • If you want to exercise some of the rights mentioned above contact us via email at market@marketing-bg.net or by mail.
  • No fee is usually required , though a reasonable fee may be charged for clearly unfounded, repetitive, or excessive requests.
  • We may request specific information to confirm your identity for security.
  • We aim to respond within one month, but will notify you if more time is needed.
  1. RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with the Supervisory Authority in Bulgaria:

  • Commission for Personal Data Protection (CPDP)
  • Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
  • Email: kzld@cpdp.bg | Website: www.cpdp.bg
  • We would appreciate it if you contact us first to try and resolve the issue.
  1. CHANGES TO THIS POLICY

We reserve the right to update this Policy on our website: www.marketing-bg.net. Significant changes will be communicated via email or other suitable contact methods.