1. INTRODUCTION

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

YOUR RESPONSIBILITIES:

• Read the General Policy.
• If you are in a contractual relationship with us, please check the related terms and/or policies: they may contain further details about how we collect and process your data.
• Please also pay attention to additional information and conditions that we introduce you to at various stages of our interaction.
• If you provide us with personal information about other people, or if others provide us with your information, we will only use that information for the specific purpose for which it was provided to us. If you provide us with information about third parties, you should have a legal basis for doing so, and you should also inform the third parties of how we will process their data.
• By providing us with data, you declare to us that you are over the age of 18 /eighteen/ years.

2. WHO ARE WE AND HOW TO FIND US?

We, “CyberXperts” AD, are the Administrator regarding your personal data and are responsible for them. Our main activity is in the field of EMPLOYMENT. As this activity is specific, we have developed separate policies for it, published further down on this page under the headings “Privacy Policy – Recruitment and Recruitment” and “Privacy Policy of workers/employees in temporary work’.
Familiarize yourself with them accordingly if you use our employment services.
If you have any questions about any of our Policies or about your personal data, please contact us.

Contact details with us:
“CyberXperts” AD, EIC: 208137120, registered office and management address: city of Sofia, district “Mladost”, g.k. “Mladost 4”, Business Park Sofia, Building 14, floor 3,
You can contact us at the above address as well as at e-mail: [email protected].
We have appointed a Personal Data Protection Officer. Contact details: [email protected].
It is very important that the information we have about you is correct and up-to-date. Please inform us of any changes or if you notice any errors.

3. WHAT DATA OF YOURS DO WE PROCESS, FOR WHAT PURPOSE AND ON WHAT BASIS?

We process personal data for specific purposes and on relevant legal grounds, depending on your role with us.
3.1 When you are a visitor or user of our website www.cyberxperts.com
A) Automatically collected information: You may access the website without entering personal data. But even in this case, certain information is automatically processed, such as log files /event files/, cookies, and analysis of the website through Google Analytics.

 

1. B) Social plugins or buttons /Social Plug-in/ Facebook, Twitter, Linkedin or others. Their use is at your discretion.These buttons represent a link to third-party sites that, using cookies, collect and process personal data according to their own policies. We are not responsible for them, but in view of your awareness and rights, we ask you to familiarize yourself with them.
   We have placed these plugins to make our website more functional for visitors, and to promote our business and services if you voluntarily share our content on the relevant sites. We accept this as our legitimate interest.

 

B.1. Information about social plug-ins used
Link about Google Analytics.
In order to continuously improve our website, we use Google Analytics, a web analytics service of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies”, which are stored on your computer and enable an analysis of the use of the website. The information generated by the cookies about your use of this website is usually sent to a Google server in Europe (or in a member state of the European Economic Area) to anonymize the IP address so that all personal characteristics are excluded. Only after it has been anonymized is the abbreviated IP address transferred to a Google server in the USA and stored there. Only in exceptional cases is it necessary to transfer and store the full IP address on a Google server in the USA. This website uses Google Analytics with an extension for the anonymous collection of IP addresses (so-called IP masking). On our behalf, Google will use the collected information to evaluate the use of the website, compile reports on website activity and provide other services related to the use of the website. The IP address transmitted by your browser in the context of Google Analytics is not combined with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser. We would like to point out, however, that in this case, you may not be able to fully use all the functions of the website. You can also refuse Google to collect the data generated by cookies related to the use of the website (including your IP address) and process this data by downloading and installing the browser plug-in available from the following link: https://tools.google.com/dlpage/gaoptout?hl=en
An opt-out cookie is created that prevents your data from being collected when you visit this website in the future.
Additional information on data protection in Google Analytics can be found at https://www.google.com/analytics/terms/bg.html and at https://support.google.com/analytics/answer/6004245?hl= en.

 

Link about social plugins
Facebook Social Plug-in: We have included a button on the social network Facebook (1601 South California Avenue, Palo Alto, CA 94304, USA – www.facebook.com ) on our website. You can recognize the Facebook buttons by the Facebook logo or the “Like” button.
As a website operator, we have no information about the content of the transmitted data or its use by Facebook. We also do not know when you clicked on any button. For more information about how Facebook uses your information, please see Facebook’s Privacy Policy https://www.facebook.com/policy.php#

 

Social Plug-in/ Instagram. We have included an Instagram button on our website. We have no information about the content of the transmitted data or its use by Instagram. We also don’t know when you clicked on any button. For more information on how Instagram uses your information, please see their terms at https://help.instagram.com/519522125107875

 

LinkedIn Conversion Tracking: On our website, we use the analytics and conversion tracking technology of LinkedIn Corporation (2029 Stierlin Court, Mountain View, CA 94043, USA – www.linkedin.com – ” LinkedIn”). With this technology, LinkedIn can show you ads based on your interests. In this way, we also receive aggregated and anonymous reports from LinkedIn about advertising activity and information about how you use our website. Further information on LinkedIn’s data protection can be found here: https://www.linkedin.com/legal/privacy-policy#choices-oblig. You can object to LinkedIn’s analysis of your behavior and the display of recommendations based on your interests by clicking “Opt Out of LinkedIn” (for LinkedIn users) or “Opt Out” (for other users) by following the following link: HTTPS: //www.linkedin.com/psettings/guest-controls/retargeting-opt-out

 

1. C) Links to other sites.
   Our site may link to other sites. If you choose to follow these links, please read the privacy policies of the respective sites in detail to understand how your information will be processed by third parties.

 

3. D) Personal data that you provide to us through the website.
   When you use our contact form or another of our services on the website, we process personal data for the purpose for which you provide it to us, i.e. according to the specific function and your request. It is in our legitimate interest to respond to your request. The mandatory fields that we have set (for example, in the contact form) are the minimum information that we have determined that we need. Please do not provide us with personal information about you that is not necessary for the relevant purpose. We also process the information that is created in view of our interaction, for example, the content itself of messages through the website.
   Sometimes we process your data on a so-called pre-contractual basis. We apply this basis in all cases in which you request to conclude a contract with us and we process your necessary data for this purpose. In other cases, there may be a concluded contract between us, and the processing of your personal data through the website is in connection with the fulfillment of our contractual obligation. If you are applying for a job with us (ie as an employee of ours, outside of our temporary employment services), please read item 3.9. below.

 

1. E) Sensitive data about you /special categories of data/.
   We do not collect such data about you. Special categories of data, or “sensitive data”, are those revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the sole purpose of identifying an individual, health data condition, sex life or sexual orientation. Please do not provide us with such data. Providing such data, as well as other personal data that is not necessary for the relevant purpose of our interaction with you, exposes your rights to unnecessary risk.

 

3. F) Combining information.
   Sometimes we combine information collected through the website with other information that we receive from you through various communication channels /for example, by email, phone/ or from other sources – public sources, such as the Commercial Register, or from third parties – rating companies, professional profiles, our partners with whom you also interact in connection with your relationship with us, for example when you have requested a service the provision of which is linked to a third party. When we combine this information, we do not use it for a different purpose of which we have not informed you.
   2. If you are a visitor to our office:
   In this case, we will ask you to introduce yourself and provide us with basic information about you /your names, organization you work for or represent/, we can also reflect the day you visited us, sometimes the specific time for this, as and information about the individuals you have met. We will use this information in view of our legitimate interest in controlling access to our office and security, and to report and monitor internally the activities of our employees with whom you meet.
   3.3. If you are a participant in our event (conference, presentation, cocktail party, charity event and others):
   We will collect the necessary information for your inclusion and participation. Sometimes we may ask for information about your preferences to make the event more enjoyable or useful for you. In some cases, events may be captured by cameras or cameras, and we may use relevant recordings or photographs, as well as information about your participation, to promote our event in the media, on our website, in a presentation or otherwise. If this bothers you, you can inform us in advance that you do not want us to publish information about you or your image.
   We will also retain basic information about you to contact you from time to time and to send you information about other similar events of ours. We may also ask you for feedback on how you rate our event. You always have the right to object to this way of using your data, as described below in relation to your rights.

3.4. If you are a participant in our promotional campaign.
Sometimes we organize such campaigns, for example through our social network profiles. In these cases, we will process the information you provide to us for the purpose of your participation in the relevant campaign.
3.5. If you “follow” us on social networks.
If you have “liked” our profile on a social network or “followed” it, according to 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 the same network to respond to you, and if you have requested that we contact you in another way / for example, by giving us your telephone number/, we will comply with your request in view of our legitimate interest in responding to your inquiry, for example.

3.6. If you are a participant in our training:
We will collect the necessary information to register you. We will process the information about your participation, presentation, exam /if such is held/.
We will also keep basic information about you in order to contact you from time to time and send you information about other such trainings of ours. We may also ask you for feedback on how you rate 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, customer or supplier or are an employee of it. In order to maintain our business relationship with the organization, we will often need information about you, for example: Your names, telephone, email, skype contact, business card, information about your position in the relevant organization. We will also process the following information: written/electronic or other correspondence with you; data contained in documentation relating to our relationship with the organization, for example your signatures, description of your conduct, your statements, etc.; any other information we need 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, customer or supplier, or are an employee of it. We may have your information from a professional public register, from a common business contact of ours who referred you, you gave us your business card or contacts at an event or meeting. In these cases, we will make an assessment for what purpose and on what basis we could use your contact details. We will take into account the context in which this occurred and your reasonable expectations regarding our use of the personal data. If we consider that we have a legitimate interest in contacting you to request a quote, propose a partnership or offer you our product or service, you will always have the right to object to such use of your data,
In some cases, we may need to ask for your consent, and you will always be able to refuse to give it.

3.9. If you are applying for a job with us:
This means that you have expressed your desire to become our employee by concluding an employment contract with us. This can be done in two cases: ( first ) when you apply for a specific position advertised 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 advertisement, in order to we will contact you if there is a suitable vacancy.
In order to take steps to consider your application, we will review the information you have submitted. If we categorically judge that you are unsuitable, we will delete your personal data within 1 /one/ week of accepting our decision to do so, but no later than 2 /two/ months from the deadline for selection for the open position.

If you apply for a particular position, but for some reason we are unable to interview or hire you for it and we wish to retain your information for the future /for other suitable positions/, we will contact you to request your consent to this.
If you do not apply for a specific position from the outset, we will assume that you have an interest in our organization as a whole. For this, if we judge, we will retain your information in order to offer you work in the future based on our legitimate interest in selecting and hiring employees who have expressed an interest in our organization. In this case, we will keep your information 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 the period of your application with us, we will also collect additional information to assess whether we wish to enter into a contract with you, for example, information related to your interview, your tests, references that you have provided to us. When we determine that you are unsuitable, we will delete information about you.
Please do not provide us with any information that is not necessary for your application with us.
3.10. For what other purposes may we use your personal data?
We have described the most typical purposes for their processing above, but you should also consider the following purposes:
– for administration of our activity, including reporting and analysis in the company itself – our legitimate interest;
– prevention of fraud and other illegal and criminal activities – our legitimate interest;
– to establish and defend legal claims – our legitimate interest;
– to fulfill our obligations under a contract to which you are not a party – our legitimate interest;
– to analyze the effectiveness of our services and activities and their improvement – our legitimate interest.
– to fulfill our obligations under a contract to which you are a party;
– to fulfill 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 to comply with our legal obligation.

3.11.2. Our legitimate interest
When we define our legal basis as a “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 discretion, you always have the right to object to processing based on legitimate interests, as described below in item 9.1.4.

3.11.3. Pre-contractual or contractual basis
When we need to take necessary steps, at your request, to conclude a contract between us or to fulfill a contract already concluded between us. In these cases, we will take care to process only your information necessary for the purpose.

3.11.4. Your agreement.
It is a freely expressed, 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 have to process your “sensitive data” on the basis of your consent, the same should also be explicitly given. In item 9.1.7. you will find out how you can withdraw your consent at any time.
Note that consent is a different legal basis than those described above. For example, signing a contract between us is not equivalent to giving consent.
If you have concerns or doubts about what exactly is the applicable basis for a specific purpose of processing your data, you can always contact us.

4. CAN YOU NOT PROVIDE YOUR PERSONAL DATA?

You are obliged to provide us with your personal data in the event that such a contractual or legal obligation exists. If in such cases you do not provide us with this data upon request, we may not be able to enter into or perform the contract or realize any of the other purposes. In any case, we will notify you of this.

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may need to share your personal data with the parties listed below:
5.1. Within our group of related companies, as far as applicable – on the basis of our legitimate interest in administering and reporting our activities.
5.2. Service providers – processing personal data. These can be hosting companies, IT service providers, system administration, couriers, mobile operators. We conclude contracts with them that guarantee the security of your data.
5.3. Other personal data controllers who provide us with relevant services – banks, auditors, lawyers, professional consultants and insurers, event organizers and others – when this is necessary for our legitimate interest to provide us with a particular service.
5.4. Public authorities that require us to declare processing activities.
5.5. Third parties to/with whom we sell, transfer or merge parts of our business or our assets – when this is necessary in view of their legitimate interest to carry out an analysis of our activity and conclude the relevant transaction.

6. INTERNATIONAL DATA TRANSFER

6.1. Your personal data is usually processed within the European Union or the European Economic Area and in rare cases is transferred to other countries (“third countries”).
6.2. If it is necessary to transfer data to “another country”, we guarantee that before such transfer the necessary level of data protection is ensured in the relevant third country or with the recipient in this third country. This may be based on a decision by the European Commission regarding the adequate level of data protection in a particular third country as a whole. Alternatively, the transfer of data may be based on the so-called “EU Standard Contractual Clauses” agreed with the recipient or, if the recipients are in the US, on the basis of the US-EU Privacy Shield Program ( EU-US Privacy Shield). Information about EU-US Privacy Shield participants can be found at www.privacyshield.gov/list. We will be happy to provide you with further information on suitable and relevant safeguards to maintain an appropriate level of data protection upon request.

7. INFORMATION SECURITY

We have implemented security measures to prevent the accidental loss, use, alteration, disclosure or access of your personal data without authorization. We also provide access to your personal data only to those employees and partners who have a specific business need to access such data.

8. DATA STORAGE PERIOD

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with legal, accounting, tax or reporting requirements.
When deciding on the exact period of data retention, we take into account its volume, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes of processing and whether they can be achieved by other means and legal requirements.

For tax purposes, we are required by law to keep basic information about our customers (including contact data, identity, financial data and transaction data) for five years /plus current/ after the relevant relationship has ended.

In many cases, we will comply with the statute of limitations under applicable law, for example, for bringing certain claims, which is in our legitimate interest.

In all cases, we take measures to restrict access to personal data at appropriate stages, in view of the ongoing processing of the data and the relevant purposes.
In some circumstances, we may anonymize your personal data for research, statistical or other purposes, in which case we may use this information for an unlimited period of time without further notice to you.

9. YOUR RIGHTS

9.1. Under certain circumstances, by law, you have the right to :
9.1.1. request access to your personal information (commonly referred to as a “data subject access request”). This gives you the opportunity to obtain a copy of the personal information we hold about you and to check whether we are processing it lawfully.
9.1.2. request correction of the personal information we hold about you. This allows you to correct and update incomplete or inaccurate information we hold about you.
9.1.3. request deletion of your personal information. This gives you the opportunity to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You have the right to ask us to delete or remove your personal information also where you have exercised your right to object to processing (see below).

9.1.4. objections to the processing of your personal data when we base the processing on our legitimate interest (or that of a third party) and there are grounds relating to your particular situation. In addition, you have the right to object when we process your personal information for direct marketing purposes, including in cases of profiling.

9.1.5. request the restriction of the processing of your personal information. This allows you to ask us to stop processing personal information about you, for example, if you want us to establish the accuracy or basis for processing it.
9.1.6. request the transfer of your personal information to another party /right of portability/.
9.1.7. withdraw your consent – in case we process personal data on the basis of your consent or express consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before it is withdrawn.
You can also see more about these rights on the website of the Commission for the Protection of Personal Data.

9.2. Exercising Your Rights.
If you wish to exercise any of the rights set out above or receive more information about it, please send us an email at [email protected], or send us a letter at our physical address.
You will not pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive, or excessive, or we will refuse to comply with your request in these circumstances.
We may need to ask you for specific information to help us verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure that ensures that personal data is not disclosed to a person who does not have the right to receive it. We may also contact you to request additional information regarding your request to expedite a response.

We try to respond to all legitimate requests within one month. Sometimes it may take us more than a month, in which case we will let you know.

10. YOUR RIGHT OF 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 relevant competent Supervisory Authority. The Personal Data Protection Commission is the Supervisory Authority of the Republic of Bulgaria, defined by the Personal Data Protection Act as follows:
Address: Sofia 1592, Prof. Blvd. Tsvetan Lazarov” No. 2, GPS coordinates: N 42.668839 E 23.377495. Center for information and contacts – tel. 02/91-53-519. Email: [email protected]. Website: www.cpdp.bg
We would appreciate it if you would contact us first, in case of a complaint, so that we can try to help you.

11. MODIFICATION OF THIS POLICY

We have the right to change and update this Policy. We will publish such changes on our website https://cyberxperts.com. If these changes are material, we will further inform you about this by email or other appropriate means of contacting you.