Cookies policy

Cookies policy

Last updated on 12/07/2024

IMPORTANT: By providing this Policy during account creation on the site https://www.kaderabotim.bg/ ("Site"), we assume that you understand how your personal data ("Personal Data") is used in The site. In the event that you are required to consent to this Personal Data Policy and its processing pursuant to this Policy, this agreement indicates your consent to the processing of Personal Data for which such consent is required in accordance with the provisions of this Policy.

This Policy aims to present to you as clearly and transparently as possible the manner in which your Personal Data belonging to you is processed. The document is in a continuous process of updating, so we recommend that you visit this page regularly to keep up to date with the most current version of the Privacy Policy.

If you have any questions about Personal Data and our Policy on their processing or suggestions to improve our services and the presentation of Personal Data information, please contact us at [email protected] and we will respond to you immediately.

IN GENERALIZATION

Through the Site, we want to provide you (you, the "User") with the opportunity to find the necessary information on the labor market, to review and evaluate your work experience with various employers ("Employers") present on the platform, and to apply for job positions, opened by these employers using your CV. To make this possible, we need to access several types of Personal Data.

This Policy contains provisions applicable both to individual Users who are interested in providing information and/or applying for jobs posted on the Site, and to Users representing an Employer on the Site.

Please read this Policy to understand the relationship between the Personal Data that you hold and the Site, and in particular: who processes and who has access to your Personal Data, for what purpose and on what basis the processing is carried out and other relevant information.

What do we mean by Personal Data? Information on the Site that we receive directly from you (for example, when you fill out a form or text field on the Site such as the registration form or other relevant feedback form, or forms that do not contain feedback about your experience with an employer), as and indirectly (for example, when using the Site from a specific device identified by a specific IP address).

Some of this information contains Personal Data (ie information that can identify you or lead to your identification). From them:

Category Personal data that is necessary for us to ensure the normal functioning of the Site (for example, the email address is necessary so that you can verify your account on the Site and thus increase the security of your account);
Category Personal Data based on our legitimate interest (we, the "Company", defined below) - for example, the name or username/pseudonym is used to limit the situations in which the User may post an anonymous review, the credibility of which would be under a question for other Users of the Site;
The last category of Personal Data is processed with your express and prior consent, and your Personal Data is stored from the moment we receive your consent. You can find more details about the processing of Personal Data in section 3 below.

Who can process Personal Data belonging to you through the Site? First of all, the legal entity that manages the Site, called "Company": Undelucram SRL, a company registered and operating in Romania. You can learn more about us and our credentials by accessing the General Terms and Conditions of the Site or by sending us an email at [email protected].

Secondly, in the development and operation of the Site we use products and services developed by Third Parties. They have the technical capacity to store and access to process and certain Personal Data provided by us through the Site, to process as intended according to the purposes defined by us. All such Third Parties and their role in the structure of the Site and the processing of Personal Data are described in section 4.1 below.

Thirdly, a substantial part of the Personal Data belonging to you is available to Employers who are active on the Site only if you have applied for jobs posted by Employers (on your own initiative) by means of a CV uploaded or created by you on The site. You can find out more about how they use your Personal Data in section 4.2 below. However, Employers do not and will not have access to information related to the identity of Users who have added employer reviews, salaries and interviews on the Platform.

All Personal Data belonging to you is processed by Third Parties that are located and process Personal Data in the territory of the European Union, or process such Personal Data in accordance with the provisions of European Union legislation. Thus, we wish to cooperate only with entities that process Personal Data through systems located on the territory of the European Union or that comply with the provisions of European Union legislation, and use services for the storage of Personal Data that offer us the possibility to storage in the territory of the European Union or in accordance with the provisions of the European Union.

You have a number of rights related to Personal Data, and we are open to helping you exercise them. You can learn more about these rights in Section 5 of this Policy.

If you have any questions or concerns about the content of this Policy, or suggestions for its improvement, you can contact us at [email protected].

This Policy is supplemented by the Terms of Access and Use of the Site, available for consultation here.

Operator details

UNDELUCRAM S.R.L., a Romanian legal entity, with its registered office in Cluj-Napoca, Str. Regele Ferdinand nr. 22-26, Centrul Comercial Central, floor 3 (correspondence address: B-dul Iuliu Maniu 6L, Campus 6.1, floor 3, Sector 6, Bucharest), registered with the Trade Registry under no. J12/2388/2019, fiscal code 37266398 (hereinafter referred to as the "Company"), holder of all rights over the Site (as defined below), respects the private nature and security of the processing of personal data of each user of the Site, being the operator of personal data, in accordance with the provisions of Law no. 677/2001 on the protection of individuals with regard to the processing of personal data and the free movement of such data and of the General Data Protection Regulation no. 2016/679 ("GDPR").

UNDELUCRAM SRL, a Romanian legal entity, with its registered office in Cluj-Napoca, Tsar Ferdinand Street No. 22-26 (address for correspondence: Bucharest, 7A Iuliu Maniu Blvd., Cotroceni Business Center, Building T, Floor 2, Sector 6), registered in The commercial register under no. J12 / 2 388/2019, fiscal code 37266398 (hereinafter referred to as "the Company"), holder of all rights to the Site (as defined below), respects the confidentiality and security of the processing of personal data of each User of the Site, having the capacity of a personal data controller, in accordance with the provisions of the Law on the Protection of Natural Persons regarding the processing of Personal Data and the free movement of such data and the General Regulation of the European Union on the processing of personal data no. 2016/679 ("RGPD")

Definitions

In this document, words used with initial capital letters have the following meanings:

a) "Site" means the site associated with the domain name www.kaderabotim.bg, the rights of which belong solely to the Company, where Users (as defined below) can find necessary information on the labor market, review and evaluate work experience with various employers registered on the Platform ("Employers", defined below) and apply for jobs posted by these Employers by means of a CV (resume);

b) "Employer" means any legal entity whose profile is available on the Site, regardless of whether this profile is active and managed by a User representing the Employer or inactive;

c) "User" means any natural person over the age of 16 who is in one of the following situations: (1) has access to the Site without creating an account on it; (2) has an account created within the Site used to be able to contribute (comment and/or rate interactions with an Employer; to upload resumes; apply to available job postings on the Site); (3) has an account created within the Site used to interact as an Employer (adding job postings; responding to comments and feedback provided by other Users); The Site is not intended for use by persons who do not meet the conditions described in this definition and, expressly, is not intended for use by minors (within the meaning of the legislation applicable to the relevant User);

d) "Third Parties" means sites other than the Company Site whose content is available on the Site, the Third Party being prominently highlighted along with the content belonging to it in the section of the Site where such content appears;

e) "Personal Data" means any information relating to an identified or identifiable natural person; an identifiable person is a person who can be identified directly or indirectly, in particular by means of an identification number or by one or more marks specific to his physical, mental, economic, cultural and social identity;

f) "Services" means a package of services provided by the Company to Employers who choose one of the two service packages available to Employers within the Site;

Processing of Personal Data and purposes of processing

For and in connection with the functioning of the Site, Personal data is processed on the basis of several legal bases with several main purposes:

3.1. Based on the legitimate interest of the Company, we process the following Personal Data:

3.1.1. the IP address of the device used to access the Site (solely for the detection of unusual activities on the Site - for example, a large number of reviews sent by a User at the same time, which complicate the operation of the Site, in order to assess whether these activities are manual or automatic, generated by a software product that tries to affect the functioning of the Site, and to take technical measures imposed by the situation);

3.1.2. the job position held by a User who represents an Employer (in order to increase the confidence of other Users regarding the information that the positions published by the Employer on the Site are positions actually offered by this Employer);

3.1.3. age and city from which the User accesses the Site, in order to summarize the data and present it to the Employers based on the Services offered by the Company; this data is not presented individually for each User and the Employer has no opportunity within the Site to find out specific information about a certain User, such as which city he comes from or what age he is, unless the User himself publishes this information;

3.1.4. the location, the job position held by a User with a particular Employer, and the period during which the User has worked for the Employer, in order to provide as accurate information as possible about the experience that the User has had. In order to protect the identity of the User, the only mandatory information among the above is the location.

3.2 Due to the need to provide certain services to Users who are active users of the Site, to maintain the normal functioning of the Site and to provide Services, we process the following Personal Data:

3.2.1. e-mail address and/or phone number (with full confirmation when creating an account, as well as sending notifications and other information to the User about activities on the Site - for example, information about activities of certain Employers followed by the User within the Site);

3.2.2. name, username/pseudonym (in order to give authenticity to the comments and reviews added by the User within the Site, which is essential for the most complete and structured presentation of the existing information on the Site about the labor market). Given the specifics of the Site, user expectations are related to finding up-to-date information and real interaction with the Employers whose profiles are available on the Site.

3.2.3. data related to the issuance of an invoice regarding the Services provided to the Employers by the Company, insofar as it contains Personal Data provided by Users representing the Employers (in order to allow the issuance of invoices related to the Services provided by the Company); this data is processed by the Company only for the time necessary to make the payments related to the Services and to reflect such payments in the accounting;

3.3 In case of quick registration on the Site via the social networks Facebook, Google and Linkedin, we process the following data: name and email address.

3.4 The site also uses cookies, which you can learn more about in the Cookie Policy.

3.5 For the avoidance of doubt, the Company does not access or use in any way the Personal Data contained in CVs uploaded to the Site.

4. Who processes the Personal Data

4.1 Company Proxies

The personal data processed through the Site are provided to the following Third Parties whose products/services are necessary for the development and functioning of the Application:

4.1.1 Google LLC, for the Google Analytics product used to analyze the city and the device from which the User accesses the Site;

The Google Analytics privacy policy is available here.

4.1.2 HotJar Ltd, for the HotJar product used to analyze the sections of the Site in which the User spends the most time;

HotJar's privacy policy is available here.

4.1.3 Claus Web SRL, for the hosting service of the Site;

Claus Web SRL's personal data processing policy is available here.

4.1.4 Cloudflare, for the Site's security service;

Cloudflare's processing of personal data is available here.

When choosing these entities, the Company takes into account their applicable regulations regarding the processing of Personal Data. In the event that the Company decides to add new or replace these objects and products, you will be notified in advance, and you will have the opportunity to refuse to use the Site if you believe that the processing of Personal Data by a certain entity may cause you harm.

4.2 For Employers

4.2.1 In order to offer Services, the Company enables Employers to activate a profile on the Site and perform several types of activities.

4.2.2 In the event that the User applies for one of the advertisements published by an Employer using his CV, the Employer has the opportunity to review all Personal Data included in that CV. Also, an Employer may withdraw such resume outside of the Company's control. We are currently evaluating the possibility of technically restricting Employers' access to Users' resumes outside of the Site.

4.2.3 In the event that the User wishes to obtain more information about the Personal Data held by the Employer, he may contact him using the contact details specified in the Employer's profile on the Site.

4.3 Term for processing Personal Data

4.3.1 Personal data provided by Users will be processed by the Company in electronic format, for the entire period during which the natural person providing the Personal Data has the role of User, as well as for the subsequent period of three years after the termination of that role by deactivating your account on the Site.

4.3.2 Personal data is stored after the period in which a natural person is a User of the Site for the purpose of researching and analyzing the activities of the Company that attract the reactivation of the account by previous Users.
4.3.3 In any case, after the deletion of the User Account from the Site and the expiration of the period specified above in point 4.3.1, the Personal Data of the relevant User will be used only for statistical and analytical purposes such as the presentation of information in a public context - information about the number of users of the Site and historical information about their activities on the Site.

User rights

Users have the following rights regarding Personal Data belonging to them, and can exercise them by sending an email to [email protected] :

5.1 Right of access to Personal Data

5.1.1 Each User may request free of charge from the Company once every 6 months confirmation of the existence of Personal Data related to the User, regardless of whether they are processed by the Company or not. If so, the Company must inform the User about: the purposes of the processing; what categories of Personal Data are processed and, to the extent that such Personal Data is not current/updated/relevant, the right to request correction, erasure or restriction of the processing of such Personal Data, or to object to the processing of Personal Data; which natural/legal entities have access to the Personal Data; the period of storage of Personal Data; the right to file a complaint with the National Authority for the Supervision of Personal Data Processing, insofar as the User considers that he cannot exercise his rights against the Operator.

5.1.2 The Company may charge a fee for providing this information in the event that the User requests are more frequent than once every 6 months; the fee to be charged will be communicated to the User at the time he makes a new request.

5.2 Right to rectification of personal data

Any User may request the Company to correct inaccurate Personal Data relating to him free of charge. If deemed necessary, after the Company's response, the User may request the completion of Personal Data, and the Company may either make the necessary changes to the User's account directly on the Site, or indicate to the User the steps by which he can make the relevant changes himself corrections.

5.3 The right to erasure of personal data

5.3.1 The User may request the Company to delete the Personal Data relating to him, after which the Company will comply with this request in the following situations:
5.3.1.1 if the Personal Data whose deletion is requested is no longer necessary for the Company to fulfill the purposes for which the information was collected or processed (for example, the User requests the deletion of a resume uploaded to the Site).

In this regard, the company will send a response to the User explaining the need to process the Personal Data given the purpose of the processing and the consequences of their deletion. In the event that the User considers that the processing of Personal Data is no longer in accordance with the purposes specified by the Company, he may retain the position of deleting Personal Data, taking responsibility for any consequences related to the use of the Site as a result of delete such Personal Data;

5.3.1.2 if the User withdraws consent to the processing of Personal Data and the Personal Data in question has previously been processed based on the User's consent as a legal basis (you can find more details about the grounds on which we process Personal Data Data in section 3 above );

5.3.1.3 if the User objects to the processing of Personal Data according to the provisions of this Policy; The Company will send a response to the User indicating whether there are legitimate reasons for further processing of Personal Data. In the event that the Company sends a newsletter to the Users or uses other methods of commercial communication, the User has the right to choose not to receive such communications at any time and regardless of the reason;

5.3.1.4 if the User believes that the processing of Personal Data has been carried out illegally; The Company will send a response to the User explaining whether there is a legal basis for the processing of Personal Data; In the event that the User considers that the processing of Personal Data is no longer in accordance with the purposes specified by the Company, he may retain the position of deleting Personal Data, taking responsibility for any consequences related to the use of the Site as a result of delete such Personal Data;

5.3.2 The Company may refuse to comply with the User's request if the Personal Data whose deletion is requested cannot be deleted due to a legal obligation regarding the Company's business (in which case the Company will indicate to the User the basis of this legal obligation) or for backup reasons (in this case, the Company will indicate to the User what measures it can take to ensure that the User's Personal Data is processed in a secure manner and at the same time that the processing is used only to provide aggregated information about the behavior of the Users of the Site).

5.4 Right to restrict the processing of personal data

The User has the right to request the Company to limit the processing of Personal Data in the event that:

5.4.1 The User indicates that the Personal Data related to him are incorrect and the Company cannot correct the specified Personal Data directly at the time of receiving the message from the User;

5.4.2 The User indicates that the processing is not legal, but does not wish to delete the data, but only to limit its processing;

5.4.3 The User indicates that he wishes the Personal Data to be accessible within the Site in order to be able to use them when appearing/exercising/establishing a right before an authority, but does not wish the Personal Data to be processed for other purposes;

5.4.4 The User disputes the legitimate interest in the processing of Personal Data (which is processed on the basis of this legitimate interest) by the Company and the Company cannot assess, after receiving the request from the User, to what extent the legitimate interest of the Company takes precedence over the right , exercised by the User.

If the right to restriction of processing will be exercised, the Company will notify the User in advance, as the case may be, before the moment when the restriction of processing is no longer applicable, the Personal Data will be processed again.

5.5 Right to request portability of Personal Data

The User may request the Company to transmit to him all Personal Data that the User has provided to the Company (therefore only the Personal Data that the User has entered directly on the Site or that relate to his preferences on the Platform), in a format that allows the User to transmit this Personal Data to a third party (for example, to request the download of the resume already created on the Site or a list of profiles of Employers followed on the Site) in order to be able to access new services or products. This right is exercised only if the data is processed according to the Agreement with the User or the performance of the contract with the User.

5.6 Right to Object

5.6.1 The User has the right to object to the processing of Personal Data that is processed based on the legitimate interest of the Company, according to the provisions of this Policy. In this sense, the User can send an e-mail to the Company at [email protected], indicating the reason to object to the processing of Personal Data concerning him (in whole or in part).

5.6.2 The Company will respond to the User within 30 days of receiving the request, indicating the extent to which it considers that the Company's legitimate interest outweighs the reason for objection stated by the User.

5.6.3 In the event that the User does not wish to receive marketing and/or promotional communications from the Company (in the event that the Company sends such communications to the User), he may opt-out at any time.

5.6.4 If the User's exercise of the right is lawful, the Company will take the necessary steps to stop the processing of that User's Personal Data;

5.7 The User has the opportunity to turn to the National Supervisory Authority for the processing of personal data, insofar as he feels harmed by the response received from the Company/lack of response to his request to exercise one of the rights specified in this Policy.

5.8 Correspondence

5.8.1 To exercise the rights mentioned above, the User may contact the Company at [email protected].

5.8.2 The Company will analyze each request individually and communicate with the User to fulfill their requests in a way that is as close as possible to the User's expectations.

5.8.3 The Company will respond to Users' requests within 30 calendar days from the date of receipt of the request. If an extension of this period is necessary, the Company will inform the requesting User of this necessity before the expiry of the initial period.

6. Confidentiality of Personal Data

6.1 The Company only uses the personal data it needs and only for the purposes described in this Policy. To the extent that it is no longer necessary for us to process certain Personal Data, we will stop processing it and we will inform you of these changes regarding the processing of Personal Data.

6.2 When processing Personal Data, the Company grants access only to Company employees/collaborators who need access to certain Personal Data to perform their activities based on their relationship with the Company.
6.3 Apart from the entities mentioned in this Policy, we will not provide access to personal data to other Third Parties without informing you in advance about this aspect.

7. Security of processing

7.1 The Company has the obligation to manage in a secure manner the Personal Data provided by the Users through the Site.

7.2 Personal data is protected as follows:

7.2.1 Regarding the ability to view and access the Personal Data, it is stored on the servers of the hosting service provider, accessible only by senior management of the Company;

7.2.2 In relation to the retention of Personal Data, in addition to its storage on the servers of the hosting service provider, there is a copy of it also stored on the same servers, accessible by password from one person of the senior management of the company;

7.3 The security of the user account is also dependent on maintaining the confidentiality of the user's login details on the platform. In this regard, the Company recommends to users:
7.3.1 Use a strong password and update it regularly;

7.3.2 Avoid using the same password for multiple applications;

7.3.3 Implementation of automated anti-virus and security systems for the information systems used to access the Site (eg anti-virus software installed on the device used to access the Site);

7.3.4 Avoid storing the User's account password in unsecured or accessible documents;

7.3.5 Avoid disclosing the User's account password details to others.
7.4 The Company shall not be liable for negligence or inaction of the User leading to the compromise of the security of the account on the Site.