Policy on the processing of personal data of job candidates

We, Tinqin АD – a company registered in the Bulgarian Commercial Register at the Registry Agency, with UIC: 203482415, having its seat and registered address at Republic of Bulgaria, Sofia (capital) Region, Sofia Municipality, city of Sofia, postal code 1784, Mladost District, 115D (In Bulgarian: 115Г) Tsarigradsko shose Blvd., building F (in Bulgarian: E), 5th floor, phone number: +359 2 805 68 98, e-mail: sofia@tinqin.com (“the Company”, “we” or “us”), are a controller of your personal data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as “GDPR”. We take seriously your privacy and the security of your personal data.

In this Policy we explain to you how we collect and use your personal data when 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 may happen in two cases: (first) when you apply for a certain position announced by us and respectively you send us your Curriculum vitae (CV) and/or cover letter (motivational letter) or (second) when you send us your Curriculum vitae (CV) and/or cover letter (motivational letter) without a specific job announcement (job ad), in order to contact you, upon the availability of an appropriate vacant position.

It is possible to submit an application for a job with us through the “CAREERS” section of the website www.tinqin.com or by sending an e-mail to careers@tinqin.com, or via a published job announcement (job ad) at www.jobs.bg or another similar job application platform, or using another method specified by us. In addition, you should bear in mind that the Privacy Policy, the Terms of Use, and the Cookie Policy are applicable with regard to the use of the website www.tinqin.com.

PURPOSES OF PROCESSING AND LEGAL BASIS FOR PROCESSING:

In order to take steps to consider your application, we will review the information provided by you. The purposes of the processing of your data are the consideration and assessment of your application, as well as the conducting of procedures for recruitment and selection of personnel. In case of processing your data for other purposes – we will inform you.

We apply the following legal bases for processing your data:

  • in order to take steps at your request prior to entering into a contract (Article 6, paragraph (1), letter (b) of the GDPR);
  • your consent to the processing of your personal data for one or more specific purposes (Article 6, paragraph (1), letter (a) of the GDPR) – in the cases specified below;
  • for compliance with a legal obligation to which we are subject (Article 6, paragraph (1), letter (c) of the GDPR) – if this basis is used, we will inform you additionally;
  • for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Article 6, paragraph (1), letter (f) of the GDPR) – in case this basis is used, we will notify you and we will inform you what the particular legitimate interests are.

SHALL YOU PROVIDE US YOUR DATA:

In general cases, you are not obliged to provide us with your personal data (you are obliged to do so only if you have such a contractual or statutory obligation). In some cases, the provision of some of your personal data is a statutory requirement and/or a requirement necessary to enter into a contract. In general cases, there is no contractual requirement for the provision of your personal data. If you do not provide us with your data, it would be possible that we could not enter into or perform a contract with you or fulfill any of our other purposes for processing your data.

STORAGE PERIODS:

Periods for storage of data when we do not hire you:

In this case, the period for storage of the personal data is 6 (six) months from the moment we receive them, unless you have given your consent for storage for a longer period. After the expiration of this period, we will erase/destroy the stored documents containing personal data, unless a special legislative act provides otherwise.

If consent is given for a longer storage period, the period for which the consent is given shall be applied. If you have given your consent, you have the right to withdraw it at any time, without affecting the lawfulness of the data processing based on consent which processing has been performed before the withdrawal of the consent. If you withdraw your consent, we will erase/destroy the stored documents containing personal data immediately after the withdrawal of consent. It is possible not to apply this rule if a special legislative act provides otherwise or if at the moment of withdrawal of consent the standard 6-month storage period /mentioned above/ has not yet expired – in such case, personal data may be retained after the withdrawal of consent, and if this happens, you will be informed by us.

When in a procedure for recruitment and selection of personnel we have requested the provision of originals or notary certified copies of documents that certify physical and psychical conformity of the candidate, the necessary qualification degree and length of service for the position to be occupied, we will return these documents to the candidate who is not approved for hiring, within 6 months from the final completion of the procedure, unless a special legislative act provides otherwise.

Periods for storage of data, if we hire you: In this case, the storage periods set out in our internal acts and procedures will be applied and we will provide you with additional notification for the processing of your data.

COLLECTION OF ADDITIONAL INFORMATION:

During the period of your application for a job with us, we will also collect additional information in order to assess whether we want to enter into a contract with you, e.g. information in connection with your interview, your tests, references that you have provided us. The above-mentioned storage periods are applied to this information as well.

Please do not provide us with information that is not necessary in view of your application to us.

FROM WHOM WE RECEIVED YOUR DATA:

If you have applied for a job with us through a party performing intermediary activity regarding employment (“Intermediary”), then we have received the information and documents related to your application from the respective Intermediary. In the other cases, we receive such information and documents from you.

RECIPIENTS OF YOUR DATA:

If you have applied for a job with us through an Intermediary, please bear in mind that:

  • after receiving your data from the Intermediary, we may ourselves provide the Intermediary with your data in connection with the process for selection of personnel and hiring you/not hiring you (for example, information whether we have concluded an employment contract with you and data about this employment contract).
  • the purposes of the above-mentioned transfer are to carry out the process for selection of personnel and you potential hiring, as well as to carry out actions in view of the performance of the agreed between us and the Intermediary and/or in view of compliance with the applicable legislation.

We will transfer your data to the above-mentioned recipient only if and to the extent that this does not infringe the applicable legislation.

We do not transfer your data to other parties outside the Company, unless we have informed you otherwise.

LACK OF AUTOMATED DECISION-MAKING:

We will not apply automated decision-making with regard to you.

WHERE IS YOUR DATA PROCESSED:

Your personal data will be processed only within the European Union or the European Economic Area.

YOUR RIGHTS:

1. According to the legislation, you have certain rights, including (but not limited to) the right to:

1.1. request access to your personal data. You have the right to obtain confirmation as to whether or not personal data concerning you are being processed. If so, you have the right to obtain access to the data and certain information related to their processing, as well as the right to receive a copy of this data.

1.2. request rectification of your personal data. You may require the rectification of inaccurate personal data concerning you and/or completion of incomplete personal data concerning you (taking into account the purposes of the processing).

1.3. request the erasure of your personal data. This gives you an opportunity to ask us to erase/remove your personal data when there is no justifiable reason for the continuing of its processing by us. You have the right to ask us to erase or remove your personal information also in the event that you have exercised your right to object to the processing (please see below).

1.4. object to the processing of your personal data. You have the right, on grounds relating to your particular situation, at any time to object to the processing of your personal data which is performed on the basis of “legitimate interest”, including in cases of profiling on this basis. In order to continue processing, we shall demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
Also, you have the right to object in the following cases:

  • You have the right at any time to object to the processing of personal data concerning you when we process them for the purposes of direct marketing, including in cases of profiling related to direct marketing. When you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  • Where personal data are processed for scientific or historical research purposes or statistical purposes, you, on grounds relating to your particular situation, shall have the right to object to the processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

1.5. request a restriction of processing of your personal data. This gives you an opportunity to ask us to stop processing (except for certain processing activities provided in the applicable legislation) personal information about you in the following cases:

  • the accuracy of the personal data is contested by you, as the restriction of processing shall be applied for a period enabling us to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  • you have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether our legitimate grounds override yours.

1.6. exercise the right to portability of your personal data. If we process personal data on the basis of “performance of a contract to which the data subject is a party” or on the basis of “consent”, you may require us to receive personal data in a structured, commonly used, and machine-readable format and/or to transmit the personal data to another personal data controller.

1.7. withdraw your consent – in the event that we process personal data on the basis of your consent or explicit consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You can also see more about these rights on the website of the Commission for Personal Data Protection: https://www.cpdp.bg/?p=element&aid=1045.

2. Exercising your rights.

If you wish to exercise any of the rights specified above or to obtain more information about it, please send us an e-mail at careers@tinqin.com or send us a letter to our physical address indicated at the beginning of this Policy. We will comply with your request if and to the extent this is provided in the applicable legislation.

YOUR RIGHT TO LODGE A COMPLAINT TO A SUPERVISORY AUTHORITY:

If you are not satisfied with any aspects of how we collect and use your data, you have the right to lodge a complaint with the respective competent supervisory authority. The Commission for Personal Data Protection is the supervisory authority for the Republic of Bulgaria, determined with the Personal Data Protection Act. Its contact details are the following: address: city of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., GPS coordinates N 42.668839 E 23.377495, tel. +3592/91-53-555, e-mail: kzld@cpdp.bg, website: www.cpdp.bg.

We would be grateful if you contact us first, in case of dissatisfaction, so that we try to help you.