Privacy notice for job candidates and trading partners

Information about the Data controller:

Legal name 5 Avenue EOOD
UIN/BULSTAT 175035393
Seat and registered office 11 Slavishte Str. , entr. B, floor 5, fl. 16A, Sofia 1421
Address of correspondence 11 Slavishte Str. , entr. B, floor 5, fl. 16A, Sofia 1421
Telephone +359 898 430 880
E-mail dpo@5-avenue.com
Website https://oneconic.com/

Information about the Supervisory authority

Legal name Commission for personal data protection
Seat and registered office 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Address of correspondence 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Telephone +359 2 91 53 518
Website www.cpdp.bg 

5 Avenue EOOD (hereinafter referred to as “Collector” or “the Company”) carries out its activity in accordance with the Law on personal data protection and Regulation (EU) 2016/679 of the European Parliament and 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.

The basis for the collection, processing and storage of your personal data

Art. 1. 5 Avenue EOOD collects and processes your personal data for the purposes of performance of a contract under Art. 6, para. 1, Regulation (EU) 2016/679, and in particular under the following:

  • To take steps at your request to sign a contract if you are a candidate for work with us;
  • To execute a contract or take steps to conclude a contract with a commercial partner;
  • Compliance with a statutory duty applicable to the Controller;
  • For the legitimate interests of the Controller or a third party.

Objectives and principles in the course of collection, processing and storage of your personal data

Art. 2. (1) When concluding a contract with a trading partner, we collect and process personal data about the names of the legal representative of the legal entity that is a party to the contract for the purposes of individualizing the party to the contract and its implementation.
(2) The contact details of the legal representative or contact person shall be official information and as such shall not be considered as personal data.
(3) Upon conclusion of a contract with a natural person, we collect and process personal data about the full name, a personal identification number and identity card (number, date of issue, publisher), for the purposes of individualization of the party to the contract and its implementation.
Art. 3. (1) We collect and process personal data, which you provide as a job candidate for work with us, for the following purposes:

  • Identification of the candidate;
  • Contacting and communicating with the candidate;
  • Selection of the candidate;

(2) We keep your personal data you have provided to us for the entire duration of the job offer, but for a period no longer than 6 months from the final completion of the recruitment and selection procedures and in case we would like to continue storing your data after this period for the purpose of further communication with you, we will send you an e-mail inquiry to give your explicit consent for the future storage of your data.
Art. 4. We adhere to the following Principles in the course of processing of your personal data:

  • lawfulness, fairness and transparency;
  • purpose limitation of the processing personal data;
  • relevance to processing goals and minimization of collected data;
  • accuracy and timeliness of the data;
  • restriction of storage in order to achieve the objectives;
  • integrity and confidentiality of the processing, and ensuring an adequate level of security of personal data.

Art. 5. When processing and storing personal data, the Controller may process and store personal data to protect its legitimate interests:

  • fulfilling its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.

What kind of data do we collect, process and keep?

Art. 6. (1) The Company carries out the following operations with the personal data you provide as job applicants for the following purposes:

  • Conclusion and execution of an employment or civil contract: For the selection of job applicants, we process the personal data you have provided to us by sending your CV.
  • Conclusion of the Impact Assessment: Given the small number of staff recruited and the limited volume of personal data being processed, there is no need to carry out an impact assessment for the current data processing operation.

(2) The Controller does not collect or process personal data that pertain to the following:

  • reveal racial or ethnic origin;
  • disclose political, religious or philosophical beliefs, or membership of trade unions;
  • genetic and biometric data, health data, or data on sexual life or sexual orientation.

(3) The personal data are collected by the Controller from the persons to whom they refer.
(4) The Controller shall not collect and process data concerning health of the candidates for employment, except after a selection for the purposes of concluding an employment contract and determining suitable working conditions.
(5) The Controller does not perform automated decision making with data.
Art. 7. (1) The Company carries out the following transactions with the personal data provided by you as legal representatives or agents of legal entities – business partners, including as natural persons – business partners, for the following purposes:

  • Conclusion and execution of a commercial transaction or contract with a client: For the conclusion and execution of a commercial transaction with a commercial entity, we process only the full names of the legal representative or the person authorized by the company, as well as the natural person – business partner pursuant to the contract.
  • Conclusion of the Impact Assessment: Given the limited scope of personal data collected and the fact that a part of it is collected from publicly available sources, we consider that an impact assessment of the operation is unnecessary.

(2) The personal data is collected by the Controller from the persons to whom they refer and also from the Commercial Register to the Registry Agency of the country where the business partner is registered.
(3) The Company does not perform automated decision making with data.

Duration of personal data storage

Art. 8. (1) The Company keeps your personal data as a candidate for work for a period of time no longer than 6 months from the final completion of the recruitment and selection procedures. Upon the expiration of that period, the Company will take the necessary care to erase and destroy all your data without undue delay or to anonymize (to bring it in a form that does not reveal your personality) unless you do not expressly agree that your data will continue to be stored and processed for the future.
(2) In case a non-selected job candidate has provided original or certified copies of documents, certifying physical and mental fitness, qualification, professional experience or other circumstances, the Company returns to the job candidate these documents in a 6 months period from the final completion of the recruitment and selection procedures.
(3) The Company keeps the personal data of the legal representatives of the legal persons – parties to the contract or the natural persons – business partners under a contract with the Company indefinitely, in order to preserve the legitimate interest of the Company and fulfil its legal obligations to state authorities and institutions.
(4) The Controller shall notify you in case the period for storing the data needs to be extended in order to comply with a statutory obligation or in view of the legitimate interests of the Controller or otherwise.

Transfer of your personal data for processing

Art. 9. (1) The Controller may, at its own discretion, transfer all or part of your personal data to data processors for the fulfillment of the processing purposes you have agreed to, subject to the requirements of Regulation (EC) 2016/679 (GDPR).
(2) The Controller notifies you in case of intent to transfer some or all of your personal data to third countries or international organizations.

Your rights with regard to collecting, processing and storing your personal data

Withdrawal of consent to process your personal data

Art. 10. (1) If you do not wish all or any of your personal data to continue to be processed by the Company for any particular or for any processing purpose, you may at any time withdraw your consent to processing by submitting a request in free text or filling in the form in Appendix No 1.
(2) The Company may ask you to verify your identity and identify yourself with the person to whom the data relate by requesting you to present an identity document on site.
(3) Withdrawal of consent does not affect the merits of processing the personal data you provide until the withdrawal of the consent.
(4) The Company may continue to process some or all of your data if there is a legal obligation to do so or for the purpose of protecting its legitimate interests.
(5) Regarding legal representatives and natural persons under a contract with the Company, para. 4 shall be applied.

Right of access

Art. 11. (1) You have the right to request and obtain from the Controller a confirmation whether personal data related to you are being processed.
(2) You have the right to access the data related to you as well as information regarding the collection, processing and storage of your personal data.
(3) The Controller shall provide you, upon request, with a copy of the processed personal data concerning you in electronic or other appropriate form.
(4) The provision of access to the data is free of charge, but the Controller reserves the right to impose an administrative fee in case of repeatability or excessive demand.

Right to rectification or completion

Art. 12. You have the right to obtain from the Controller:

  • rectification of inaccurate personal data concerning you;
  • to have incomplete personal data, concerning you, completed.

Right to erasure (‘right to be forgotten’)

Art. 13. (1) You have the right to obtain from the Controller the erasure of personal data concerning you and the Controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw your consent on which the processing is based and where there is no other legal ground for the processing;
  • you object to the processing of personal data concerning you, including for the purposes of the direct marketing and there are no overriding legitimate grounds for the processing;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased in order to comply with a legal obligation under European Union law or a Member State law to which the Controller is subject;
  • the personal data have been collected in relation to the offer of information society services.

(2) The Controller is not obliged to erase the personal data if he collects and process them:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing under European Union law or a Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested to the Controller;
  • for reasons of public interest in the area of public health;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
  • for the establishment, exercise or defence of legal claims.

(3) In the event that you exercise your right to be forgotten, the Company will delete all your data except for your three names as a jobseeker for reporting purposes.
(4) The data of legal representatives and natural persons under contract with the company shall continue to be preserved and processed despite a request for erasure, on the grounds of compliance with a legal obligation of the company, observance of the legitimate interest and establishment, exercise or protection of legal claims.
(5) In order to exercise your right to be forgotten, it is necessary to send a request in free text or to fill in the form in Appendix 2 and to identify yourself with an identity document on the spot.

Right to restriction of processing

Art. 14. You have the right to obtain from the Controller restriction of processing where one of the following applies:

  • the accuracy of the personal data is contested by the data subject, for a period enabling the controller 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;
  • the controller no longer needs 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 pending the verification whether the legitimate grounds of the controller override those of yours.

Right of portability

Art. 15. (1) If you have consented to the processing of your personal data or the processing is necessary for the execution of the agreement with the Controller, or if your data is processed in an automated manner, you may, after you certify your identity before the Controller:

  • ask the Controller to provide you with your personal data in a readable format and transfer it to another Controller;
  • ask the Controller to transfer your personal data directly to another controller you choose when it is technically feasible.

(2) You may exercise your right of portability by sending a request in free text or by filling in the form in Appendix 3.

Right to receive information

Art. 16. You may request the Controller to inform you of all recipients to whom the personal data for which the correction, erasure or restriction of the processing has been requested and has been disclosed. The Controller may refuse to provide this information if this would not be possible or would require disproportionate effort.

Right of objection

Art. 17. You may object at any time to the processing of personal data by the Controller that apply to you, including if it is being processed for profiling or direct marketing purposes.

Your rights to violate the security of your personal information

Art. 18. (1) If the Controller detects a personal data breach that may pose a high risk to your rights and freedoms, he shall notify you without undue delay of the violation and of the measures taken or to be taken.
(2) The Controller is not obliged to notify you if he:

  • has taken appropriate technical and organizational measures to protect the data affected by the breach of security;
  • has subsequently taken measures to ensure that the violation will not lead to a high risk for your rights;
  • notification would require disproportionate efforts.

Persons, to whom your personal data is provided

Art. 19. For the purpose of processing your personal data and executing the contract, the Company may provide your data to third parties processing personal data that comply with all legal and security requirements for the processing and storage of your personal data.
Art. 20. The Controller does not transfer your data to third countries.
Art. 21. In case of violation of your rights according to this Privacy notice or the applicable law, you could file a complaint before the Commission for personal data protection:

Legal name Commission for personal data protection
Seat and registered office 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Address of correspondence 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Telephone +359 2 91 53 518
Website www.cpdp.bg 

Art. 22. You may exercise all of your rights to protect your personal data through the forms enclosed with this information. Of course, these forms are not mandatory and you can make your request in any form that contains a statement about it and identifies you as the data subject.

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