Your personal data are very important to us and we make all reasonable efforts to undertake the necessary measures to preserve your privacy. We invite you to carefully read this Privacy Notice, which outlines the basis on which Smartcom processes your personal data as well as your rights in respect of such personal data.

Smartcom - Bulgaria AD is a trade company registered with the Commercial Register at the Registry Agency under UIC 130985811, with registered office and address: 1421 Sofia, 20 Lozenets str., website: smartcom.bg (“Smartcom”).

Smartcom is the data controller in respect of the personal data it collects and holds about you as part of the recruitment process.

The data subject is a job applicant, who participates in the recruitment process of Smartcom.

1. Personal data we process

The categories of personal data we may collect and process about you include:

·  your name, address and contact details, including email address and telephone number;

·  personal details such as date of birth and nationality;

·  information regarding your educational background, qualifications, skills, experience and employment history;

·  recruitment documentation, such as interview notes and results from tests for qualifications when Smartcom conducts such tests in the course of the recruitment procedures.

Smartcom collects this information on the basis of documents, such as CV and cover letter, and information provided personally by you via interviews, tests and other means of evaluation. Smartcom may also collect personal data concerning you from third parties, such as former employers, referents, etc.

Smartcom does not request to receive from you any sensitive personal data revealing racial or ethnical origin, political views, religious or philosophical convictions, trade union membership, data concerning health or sexual orientation, so please do not submit such information in your application. 

2. Purposes of personal data processing

Your personal data are only processed for the purpose of managing the recruitment process in order to communicate with you and to evaluate your profile according to our recruitment needs. This process may encompass interviews, tests, references and informing you of other job openings based on your CV. 

3. The basis for personal data processing

Smartcom processes your personal data based on your informed and freely given consent, which you unambiguously express, by voluntarily providing your personal and professional information for the purposes of the recruitment process.

4. Storage. Access to and sharing of your personal data

Your personal data will be stored within the European Economic Area (“EEA”) and will not be transferred and processed in countries outside the EEA. Your data will be stored both on paper and in electronic format.

Your personal data will be accessible to Smartcom’s employees whose functions are related to recruitment and HR processes. The access of such employees to your personal data is made to the extent and volume necessary for the performance of their labour functions and duties. These employees are bound by valid obligations for confidentiality and non-disclosure of the personal data accessed by them.

Smartcom will not disclose your personal information to third parties unless this is required by law. We do not sell, make commercial arrangements, or otherwise outsource processing of your personal data.

5. Data security

Smartcom maintains appropriate technical and organizational measures against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unlawful access to personal data.

6. Data retention 

If your job application at Smartcom is successful, we will retain the personal data we have about you, in order to process them in the context of your employment relationship with Smartcom. The periods for which your data will be held will be provided to you in the Privacy Notice for employees, which will be given to you at the time of execution of an employment contract with Smartcom.

If your job application is unsuccessful, Smartcom will keep your personal data in compliance with Bulgarian law for a period no longer than 6 months as of termination of the recruitment process or after expiration of the term for its contesting. The purpose for this is to contact you, if there are new vacant positions at Smartcom, which according to us, correspond to your profile.

7. Your rights

You have the right to withdraw your consent for the processing of your personal data at any time. If you do so, Smartcom will not be able to go further in the recruitment process with regard to your application. You can withdraw your consent by sending an email with your request to: privacy@smartcom.bg.

You have the following rights with respect to the processing of your personal data:

·  right of access - to request access and obtain a copy of your data;

·  right of rectification - to request Smartcom to change incorrect or incomplete data about you;

·  right of erasure ("right to be forgotten”) – to request Smartcom to delete your data when they are no longer necessary for the purposes of processing; please note that we may reject or restrict the request in some circumstances depending on the information we process and the lawful reason to keep the data;

·  right to restrict processing – to request that we do not use the personal data you have provided (e.g. if you believe them to be inaccurate or they are no longer needed);

·  right to object – to object to certain processing of your personal data unless we have overriding compelling grounds to continue processing;

·  right to data portability - to request Smartcom to provide you with a copy of your personal data in a structured commonly used and machine-readable format as well as to request us to transmit your personal data directly to another controller, when this is technically feasible.

The rights listed here are not absolute and there may be an exceptions in cases provided by law. We will ensure to provide you with explanations regarding such exceptions when you contact us.

If you are willing to exercise any of the rights specified above, you may contact Smartcom as set out below.

8. Contact information

If you are willing to exercise your rights under Art. 7 above or if you have any questions with respect to this document, please contact Smartcom as follows:

• address: BIC IZOT, Building 1, Floor 3, Office 317, 133 Tzarigradsko Chaussee Blvd., 1784 Sofia

• phone: +359 (2) 9650650

• e-mail: privacy@smartcom.bg

If you think that Smartcom processes your personal data in breach of the applicable data protection legislation, you have the right to submit a complaint to the Personal Data Protection Commission: 1592 Sofia, 2, Tsvetan Lazarov Blvd.; www.cpdp.bg; kzld@cpdp.bg.

9. Updates to our Privacy Notice

We may need to update our Privacy Notice periodically to provide you with the most accurate information about processing of your data and ensuring compliance with the applicable law. Any update of this document will be posted on our website. If we materially change the way in which we process your personal data, for example the purpose of why we use your personal data, the identity of the Controller or your rights, you will be notified via email or SMS.