PERSONAL DATA PROTECTION POLICY

Update date:

Personal data protection policy of New Start HR services EOOD, registered with the Commercial Register at the Registry Agency with Unique ID Code 201895696, having its registered office and principal place of business at: Rakovski county, Rakovski municipality, Rakovski city 4150, residential quarter Filip Stanislavov 14, implementing consultancy and intermediation business relating to hiring of personnel, informing and employing in the country and abroad, administration of salaries and payments, leasing services, including in relation to hiring of personnel, organizing and conducting training courses and seminars, including with international participation, hereinafter referred to as the “Policy”.

New Start HR services EOOD processes personal data of natural persons – customers of New Start HR services EOOD, its employees or other natural persons listed below (“Data Subjects”, “You”) for the purpose of providing services (“Services”), in conformity with the present Policy and the internal rules of keeping the individual Personal Data Records.

When processing personal data, New Start HR services EOOD complies with all applicable regulatory acts relating to protection of personal data, including, but not limited to Regulation (EU) 2016/679 (“Regulation”), and with the present Policy it aims to inform the interested parties about the purposes of personal data processing, the grounds for processing such data, the categories of recipients to whom such data may be disclosed, and Your rights.

By definitions:

A Personal Data Record is any structured pool of personal data, which is accessible based on specific criteria, in accordance with the Internal Rules of record keeping of New Start HR services EOOD, which may be centralized or decentralized, and is distributed based on a functional principle.

1. Purposes of personal data processing

New Start HR services EOOD collects the data provided personally by You in relation to implementing the subject of its business, including hiring of employees and provision of services by New Start HR services EOOD. All activities relating to processing of personal data are documented, in accordance with the Internal Rules of activities relating to personal data processing, in the individual personal data records. Personal data is collected for the purpose of compliance with the statutory obligations of New Start HR services EOOD, protection of the legitimate interests of New Start HR services EOOD pursuant to applicable laws, and fulfilment of any concluded agreements.

1.1. Conclusion and fulfilment of an agreement. These are the purposes required for the steps relating to conclusion and fulfilment of the agreement between You and New Start HR services EOOD, including the processing of personal data necessary for registration and for the activities relating to provision of Services, available through the website. In addition, these purposes include any communication with You, including by e-mail, which is necessary in relation to provision of Services and/or notifying You of any changes to the Services provided. To that end, it may be necessary to process some or all of the aforementioned categories of data.

1.2. Legitimate interest. The purposes relating to the legitimate interests of New Start HR services EOOD include:

• Ensuring the normal functioning and use of the Website by You, support and administration of Services, resolution of any occurring disputes, identification and prevention of any malicious actions;
• Implementation and protection of the rights and legal interests of New Start HR services EOOD, including in court, and rendering of assistance for implementation and protection of the rights and legal interests of any other users of the website and/or any affected third parties.
• Communicating with You, including through electronic means;
• Receipt and processing of any received alerts, complaints, claims and any other correspondence.

1.3. Statutory obligations

Such purposes include:

Financial and accounting activities necessitating the processing and storing of information required by law in view of compliance with any tax, accounting or other reporting obligations;

• Activities relating to compliance with any statutory obligations for retention or submission of information;
• Activities relating to fulfilment of obligations for documentation, reporting obligations and any other obligations with regard to compliance with the requirements of Regulation (EU) 2016/679 and the current laws, including in relation to the obligations assigned through the Personal Data Processing Agreement, and any other applicable obligations.

1.4. Explicit consent. Your data can also be processed based on Your explicit consent, whereas in this case the processing is specific and within the scope stipulated in said consent.

New Start HR services EOOD processes personal data only in compliance with the present Policy and to the extent permitted by law. The information is collected when You register on the website.

2. Personal data collected, stored and processed by New Start HR services EOOD in the “Natural Persons” Record. Storing duration

Personal data	Purpose	Storing duration
Name	Conclusion and fulfilment of the agreement with New Start HR services EOOD, legitimate interest	Up to 3 years following the termination date of the agreement
Personal ID	Conclusion and fulfilment of the agreement with New Start HR services EOOD, legitimate interest	Up to 3 years following the termination date of the agreement
Address, telephone number, e-mail	Conclusion and fulfilment of the agreement with New Start HR services EOOD, including receipt and processing of complaints and alerts, improving the quality of services provided by New Start HR services EOOD, legitimate interest	Up to 3 years following the termination date of the agreement
Other data voluntarily submitted by You	Fulfilment of the agreement by New Start HR services  EOOD	Up to 3 years following the termination date of the agreement
Website use logs	Fulfilment of the agreement by New Start HR services EOOD	Up to 1 year following the date of IP, date and time, use of the Website (i.e. how You interact with our Website), information about your device (for example, screen size), location
Personal data of employees	Compliance with statutory obligations and the employment agreement	For the duration stipulated in the social security legislation

3. Website

Use of the webpage empowerbulgaria.com is possible without the need for registration and submission of any data by any user.

The personal data, submitted by You, will be processed for the purposes of provision of information about the services of New Start HR services EOOD, as well as for the purposes of customization of the webpage in relation to your needs and improvement of the webpage. New Start HR services EOOD may submit some of the received data to other third parties in relation to fulfilment of your orders and requests.

The services provided on this webpage are intended for people over the age of 18. New Start HR services EOOD does not collect, use or disclose personal data of minors without the preliminary consent of a parent or guardian.

New Start HR services EOOD declares that it complies with the laws in the field of child protection.

4. Rights with regard to personal data

As a natural person, who is a data subject, You have the following rights:

4.1. Right to be informed

This Policy is intended to inform You in details about the processing of your personal data in relation to the Services provided.

4.2. Right to access 

You are entitled to receive confirmation whether your personal data is processed, access to such data and information about its processing and your rights in this respect.

4.3. Right to correct

You are entitled to correct your personal data, if it is incomplete or inaccurate.

Your personal data can be corrected by You and/or your authorized representative.

4.4. Right to delete

You are entitled to request deletion of data, except in case of legal grounds and/or statutory obligations for its processing.

4.5. Right to restrict in relation to data processing

The Regulation stipulates an option to restrict the processing of your personal data, if the respective grounds for it are present.

4.6. Right to notify third parties

If applicable, You are entitled to ask New Start HR services EOOD to notify any third parties to whom it has submitted your personal data, with regard to correction, deletion or restriction of the processing of your personal data.

4.7. Right of portability of the data

You are entitled to receive the personal data which You have submitted and which refers to You in a structured, machine-readable format, as well as to use such data for any other controller at your discretion.

4.8. Right to not be the subject of any decision based only on automated processing, including profiling, which gives rise to legal consequences for You or similarly affects You to a substantial degree, except in the presence of the respective grounds for it, as stipulated in the applicable personal data protection laws, with appropriate guarantees for protection of your rights, freedoms and legitimate interests.

The provision of Services does not involve any technologies pertaining to this category.

4.9. Right to withdraw consent

You are entitled, at any time, to withdraw your consent for the processing of personal data, which is based on the consent given by You. Such withdrawal does not affect the legality of processing based on the given consent up to the moment of its withdrawal.

4.10. Right to object

You are entitled to object with regard to any data processed based on a legitimate interest.

Upon receipt of such objection, we will review your request and if it is well-founded, we will comply therewith. If we consider that there are convincing legal grounds for the processing or that it is necessary for establishing, exercising or protecting any legal claims, we will inform you respectively.

5. Contact person with regard to personal data protection

If you have any questions in relation to this Policy, please direct your inquiry to the following address: hr@newstarthr.com.

6. Non-disclosure of personal data

New Start HR services EOOD collects personal data only in conformity with the laws in relation to protection of personal data. Except in the cases stipulated in this policy, no personal data will be submitted to any other third parties. If it is necessary to submit your personal data to contracting parties of New Start HR services EOOD in relation to any Services provided by New Start HR services EOOD and its contracting parties, such data will be processed only in compliance with the requirements of the laws and in relation to the requested services.

It is possible for certain personal data to be disclosed to the competent authorities by virtue of any law, court ruling or any other relevant deed, and/or if such disclosure is required for uncovering any crimes in the country and/or abroad.

7. Liability

New Start HR services EOOD shall not be liable for the personal data processing policies of any webpages links to which are contained in this webpage.

8. Confidentiality

When processing any personal data, New Start HR services EOOD undertakes all necessary measures to protect the information against loss, abuse, disclosure, alteration or destruction.