Privacy Policy

‍Last updated: August 1, 2025

1. Introduction

This Privacy Policy (“Policy”) governs the relationship between you, the Users of our website, and HRS Recruitment Services Ltd., a company registered in the Commercial Register with the Registry Agency under UIC 205038277, having its registered office at 11-13 Yunak Street, Floor 2, Sofia, Bulgaria. The company is licensed by the Bulgarian Employment Agency under License No. 2525/26.04.2018 and is represented by its Managing Directors, Georgi Hristov Angelov and Kiril Ivov Boradjiev (“HRS,” “we,” “us,” or “the Controller”), in its capacity as the data controller of the website https://www.hrs-bg.com.

HRS places great importance on protecting your personal data and collects and processes such data only in compliance with applicable local and European legislation. The purpose of this Policy is to inform you about how we process your personal data, what types of personal data we may collect, the purposes for which we use it, the retention periods, and your rights.

This Policy fully complies with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any other applicable data protection laws. Any changes to this Policy will be duly reflected on our website, with the “last updated” date at the top of this document amended accordingly, and users will be notified via the email addresses they have provided.

If you do not agree with any part of this Policy, please do not register on our website and do not use our services. Your continued use of the website after any changes will be deemed as your acknowledgment and acceptance of our updated Privacy Policy.

2. Definitions

For the purposes of this Policy:

Data Controller means a natural or legal person who alone, or jointly with others, determines the purposes and means of processing personal data.
Company refers to HRS Recruitment Services Ltd., the Controller of the platform.
Personal Data means any information relating to an identified or identifiable natural person (“you,” “your,” “data subject,” “candidate,” or “user”).
Processing means any operation or set of operations performed on personal data.
Processor means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Controller.
Recipient means a natural or legal person, public authority, agency, or another body to whom the personal data is disclosed.
Personal Data Breach means a security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

3. Data Controller

The Company processes the personal data of website users as an independent Controller. Employers are also considered independent Controllers with respect to the candidate data they receive.

We collect and process personal data relating to:

Job candidates who have applied directly with us;
Candidates we recruit or place with our clients (employers);
Users of our website https://www.hrs-bg.com/en/submit-cv;
Candidates applying via our partner platforms such as jobs.bg, zaplata.bg, rabota.bg, etc.;
Visitors (e.g., video surveillance data collected at our premises).

4. Personal Data We Collect

Depending on the services you use, we may collect and process:

Full name
Date of birth
Email address and/or physical address
Phone number
Education and qualifications, including language skills
Employment history and previous employers
Work permit details
Correspondence exchanged with us, including preferences and settings
CCTV footage when you visit our offices (for security purposes)
Audio recordings and/or transcripts from interviews conducted with our AI-powered voice agent
Content of answers provided during AI interviews
Metadata from AI interviews (e.g., date, time, duration, session ID)
Other data provided via contact forms

When you use our website, we may also collect:

Username and password for resources administered by HRS or authorized third parties
Email address, account activity data
Other information you choose to share voluntarily

We do not intentionally collect sensitive personal data (e.g., racial or ethnic origin, religious beliefs, sexual orientation). If such data is inadvertently provided, it will not be stored.

5. Purposes of Processing

We process your data solely for the purposes for which it was collected, in line with our core business activities—recruitment, consultancy, analysis, and career support.

Specific purposes include:

Contract conclusion and administration
Providing employers with access to our database
Candidate pre-selection, including the use of AI-powered voice agents for structured interviews
Managing financial transactions
Processing applications and requests
Connecting candidates with employers
Sending job alerts
Business evaluation and improvement
Delivering additional services such as training and career counselling
Assessing suitability for employment
Ensuring effective communication and security

6. Legal Basis for Processing

We may process your personal data based on:

Contract performance or steps prior to entering into a contract
Compliance with legal obligations
Our legitimate interests (e.g., CCTV for security)
Your explicit consent (e.g., for data transfers outside the EU, direct marketing, participation in AI interviews)

We may share your data with:

Accounting firms, law firms, IT service providers, and website maintenance providers
Government authorities (e.g., Employment Agency, National Revenue Agency, Ministry of Interior) when legally required

7. Use of AI Voice Agents in Recruitment

In certain projects, we use AI-powered voice agents for early-stage structured interviews to gather objective information (e.g., language proficiency, work preferences).

Participation is voluntary. You have the right to:

Choose an interview with a human recruiter
End the AI interview at any time
Request deletion of the recording and transcript

Activation of the AI interview only occurs after your explicit consent, e.g., clicking “Smart Apply” or other clear opt-in action.

8. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects.

9. Methods of Data Collection

We collect personal data via:

In-person applications at our offices
Our website
Public job platforms (e.g., jobs.bg, zaplata.bg, rabota.bg)
Social media channels (e.g., Facebook, LinkedIn)
Events, phone calls, email
Applications submitted during recruitment processes

10. Data Retention & Security

We may transfer your data outside the EU only with your explicit written consent or under lawful derogations.

We implement physical, organizational, and technical safeguards, including encryption, pseudonymization, access controls, staff training, secure storage, and strict confidentiality obligations.

11. Data Deletion

We delete personal data when retention periods expire, unless legal requirements mandate otherwise. Examples:

5 years for candidates (per Bulgarian recruitment regulations)
Up to 3 years for direct recruitment by employers
10 years for accounting data (per Bulgarian accounting law)
30 days for CCTV footage

12. Your Rights

You have the right to:

Opt out of marketing communications
Access your data in a machine-readable format
Correct, update, or delete your data
Request data portability
Request erasure (“right to be forgotten”) subject to legal exceptions
Receive detailed information about our processing activities
File a complaint with the relevant data protection authority

Contact for data rights requests:
Email: dataprotection@hrs-bg.com
Phone: +359 2 419 1414

13. Data Sharing

We may share your data with:

AI voice agent providers for interview purposes (with appropriate safeguards, including Standard Contractual Clauses for transfers outside the EU)
Employers using our platforms, who will have access to your profile (CV, contact details, career history, qualifications, certificates, test results, and any other voluntarily provided information)
Authorities or third parties when legally required or in cases of fraud prevention, corporate transactions, or protection of our rights and security

14. Changes to This Policy

We may update this Policy from time to time. Updates will take effect immediately upon publication. Regularly reviewing this page ensures you are aware of what information we collect, how we use it, and under what circumstances it may be shared.

15. Supervisory Authority

The relevant supervisory authority in Bulgaria is:
Commission for Personal Data Protection
2 Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Phone: +359 2 915 3580
Fax: +359 2 915 3525
Email: kzld@cpdp.bg
Website: www.cpdp.bg

For questions about this Policy, contact us at: info@hrs-bg.com

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