“JOBTIGER” Ltd. processes personal data in order to provide a comprehensive range of professional services related to job search and recruitment. Data subjects are legally capable natural persons.
“JOBTIGER” Ltd. owns and operates the platform JobTiger.bg, where jobseekers and employers communicate directly by publishing job advertisements, uploading CVs, applying for vacancies and exchanging information related to the labour market. In these cases, personal data are processed on the basis of Article 6(1)(a) and/or Article 6(1)(b) of Regulation (EU) 2016/679 of 27 April 2016.
Who Is the Data Controller When Applying for Jobs
Applications to employers’ job postings (Employer as Data Controller)
When you apply for a job advertisement published by an employer on JobTiger.bg, the respective employer acts as the data controller and processes your personal data for recruitment and hiring purposes (pre-contractual relations), including evaluation of your application and communication with you.
In such cases, “JOBTIGER” Ltd. provides the technical platform and processes personal data as a processor on behalf of the employer in order to receive, store and make your application available through the platform’s functionalities.
After receiving the application, the employer may store a copy in its own systems and determine its own retention periods and privacy policies. We recommend that you review the employer’s data protection information, where available (e.g. career page or privacy policy).
“JOBTIGER” Ltd. is registered with the Bulgarian Employment Agency as a licensed employment intermediary operating in Bulgaria and abroad and provides mediation services within the meaning of Article 26 of the Employment Promotion Act through the website jobtiger.agency. In this capacity, personal data are processed on the basis of Article 6(1)(e) of Regulation (EU) 2016/679.
The security of personal data is a core priority for “JOBTIGER” Ltd. Appropriate technical and organisational measures are applied in accordance with legal requirements and the assessed risk to the rights and freedoms of data subjects.
for the legitimate interests of the company as a licensed labour market intermediary;
based on the data subject’s consent, which may be withdrawn at any time;
where necessary for the performance of a task carried out in the public interest;
where necessary for the company’s legitimate interests, including providing innovative, personalised, secure and sustainable services, unless such interests are overridden by the data subject’s fundamental rights and freedoms.
Personal data are processed for the following purposes:
to verify and/or establish the identity of the data subject;
to manage and deliver the requested services and to perform service agreements;
to notify you about matters related to the services you use; to send various notices; to inform you about issues or errors; or to respond to submitted requests, complaints, or suggestions;
Where the legal basis for processing is Article 6(1)(a) of Regulation (EU) 2016/679, the data subject provides explicit consent for the processing of their data for the purposes stated above (job search and job matching). The data subject may withdraw their consent at any time; such withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal. Withdrawal of consent does not affect the performance of “JOBTIGER” Ltd.’s contractual obligations.
Definition
For the purposes of this Privacy Policy, an “application” means the data and files you provide when applying for a job advertisement (e.g. email address, names, CV/cover letter, messages, and technical metadata related to the submission).
Applying for a job advertisement published by an employer
When you apply for a job advertisement published by an employer on JobTiger.bg, the employer acts as the data controller for recruitment and hiring purposes.
“JOBTIGER” Ltd. provides the technical platform and processes the data as a processor on behalf of the employer, in accordance with Article 28 of Regulation (EU) 2016/679 and the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/915.
After your application is made available to the employer, the employer may store the data in its own systems and determine its own retention periods and processing purposes, for which “JOBTIGER” Ltd. does not act as a controller and bears no controller responsibility.
Categories of personal data
The personal data we typically process include your name, email/username, password (when creating an account on a “JOBTIGER” Ltd. website), as well as information included in your CV such as contact phone number, gender, age, address, educational/professional identity, online identifier, etc., depending on the specific case.
When applying for a job, you decide what personal data to include in the relevant files, including information that may constitute sensitive data or special categories of personal data.
Retention periods
Job applications and the attached files (CV and/or cover letter and photo, where applicable) are stored by “JOBTIGER” Ltd. for 6 months after the expiry of the job advertisement to which the application was submitted, or until the applicant deletes the application via the relevant functionality in their account.
After the application is provided to the employer, the employer may store the data for a longer period in its own systems in accordance with its own retention rules and legal obligations. For such processing, “JOBTIGER” Ltd. does not determine the purposes and means and does not bear controller responsibility.
Saved search / job email alerts
Subscriptions by registered users for job email alerts based on criteria selected by you (“saved search”) are stored until you delete the criteria and unsubscribe from emails, or until the account is deleted.
Subscriptions by non-registered users for job email alerts based on criteria selected by you (“saved search”) are stored for 6 months, after which they are deleted automatically, unless you unsubscribe earlier.
Jobseeker account
A jobseeker’s account is deleted if it has not been used for two years, or upon the user’s request via the account deletion functionality. If the user is subscribed to the newsletter, they will continue to receive it until they unsubscribe; in such case, the personal data processed for that purpose will remain limited to name and email address.
When applying for a job without registration, a system-generated jobseeker profile is created automatically. The non-registered applicant receives an email confirmation of the successful application, the position title, and a link to create a registered jobseeker account in order to access the system-generated account and review their applications.
System-generated profiles for non-registered users are deleted automatically 6 months after the expiry of the job advertisement to which the user applied.
Employer account
An employer account is deleted if it has not been used for five years. If the user is subscribed to the newsletter, they will continue to receive it until they unsubscribe; in such case, the personal data processed for that purpose will remain limited to name and email address.
Job advertisements, whether paid or free, are deleted from the employer account within 5 years from their creation date.
Newsletter
Newsletter subscriptions are stored until you unsubscribe from receiving emails (e.g. via the unsubscribe link included in each newsletter).
Email Communications and CRM
For sending system, transactional, and marketing emails, as well as for managing customer relationships (CRM), “JOBTIGER” Ltd. uses the Brevo platform.
Brevo is used for the following purposes:
sending transactional and system messages (e.g. registration confirmation, job application confirmation, saved search notifications);
sending newsletters and marketing communications to individuals who have provided consent or where another lawful basis applies;
managing contacts and clients – legal entities and their representatives – within a CRM system.
Marketing communications are sent only where a valid legal basis exists. Each recipient may unsubscribe at any time via an unsubscribe link included in every message.
“JOBTIGER” Ltd. may process contact details of representatives of legal entities obtained from publicly available sources (e.g. company websites, commercial registers, professional platforms) solely for B2B communication related to the offering of services, events, or partnerships, in compliance with applicable legislation and the right to object.
Data Protection
“JOBTIGER” Ltd. processes personal data lawfully. Such processing is necessary in order to achieve the purposes of providing job search and recruitment services in Bulgaria and abroad. Without these data, the relevant services could not be provided by “JOBTIGER” Ltd.
To ensure an adequate level of data protection, “JOBTIGER” Ltd. applies all necessary organizational and technical measures provided for in:
the Personal Data Protection Act;
Ordinance No. 1 of 30 January 2013 on the minimum level of technical and organizational measures and the admissible type of personal data protection;
the guidelines and opinions of the Article 29 Working Party;
the guidance and practice of the Bulgarian Commission for Personal Data Protection.
“JOBTIGER” Ltd. has established internal structures and procedures aimed at preventing abuse and security breaches.
In order to achieve a high level of security when processing personal data, “JOBTIGER” Ltd. may apply additional safeguards such as encryption, pseudonymisation, and other appropriate technical solutions.
“JOBTIGER” Ltd. ceases the use of personal data in line with the originally defined purposes:
where processing is related to a contractual relationship – after termination of the contract with the data subject, without deleting the data prior to the expiry of statutory retention periods;
where processing is based on consent – after withdrawal of consent, with the data being deleted without undue delay, unless longer retention is required by law.
Statutory retention periods are determined by, including but not limited to:
the Electronic Communications Act;
the Accounting Act;
the Obligations and Contracts Act;
legal acts requiring the provision of information to courts or competent public authorities.
Notwithstanding the above, deletion or anonymisation of personal data is not carried out where such data are necessary for ongoing judicial, administrative, or complaint-handling proceedings involving the data subject.
Cookies, Tags and Advertising Technologies
We use a cookie consent management platform (Cookie Script) that allows you to manage cookie categories and related technologies (e.g. analytics and marketing).
Depending on your choices (consent/settings), third-party technologies such as Google Tag Manager, Google Analytics 4, Google Ads, and Google Ad Manager may be activated on the website for the purposes of traffic measurement, performance analysis, and/or displaying and measuring advertising.
Where applicable, these technologies are activated only after your explicit choice/consent, unless a specific cookie or script is strictly necessary for the operation of the website.
Recipients of Personal Data
Personal data may be disclosed to the following categories of recipients (data controllers):
public authorities, institutions, and persons to whom we are legally obliged to disclose personal data;
other data controllers in connection with the exercise of the right to data portability;
employers who have published a job posting you apply for – acting as data controllers for recruitment and hiring purposes;
service providers such as cloud infrastructure and hosting providers (e.g. Microsoft Azure), email service providers (e.g. Brevo), consent management platforms (e.g. Cookie Script), analytics and advertising service providers (Google – GTM, GA4, Google Ads, Ad Manager), and security service providers (e.g. ESET), to the extent necessary for the provision and protection of the services.
Transfers Outside the EEA / International Transfers
Some of our service providers (e.g. cloud infrastructure, email, analytics, and advertising providers) may process personal data outside the European Economic Area (EEA) or provide access from third countries.
In such cases, “JOBTIGER” Ltd. applies appropriate legal mechanisms and safeguards in accordance with Regulation (EU) 2016/679, such as Standard Contractual Clauses and/or other applicable transfer mechanisms, as well as additional protective measures proportionate to the identified risks.
Rights of Data Subjects
Right to Information
Data subjects have the right to request:
confirmation as to whether personal data concerning them are being processed, information on the purposes of processing, the categories of data, and the recipients or categories of recipients;
a copy of the processed personal data in an intelligible form, as well as any available information on their source.
Right to Rectification
Where incomplete or inaccurate data are processed, data subjects have the right at any time to request that “JOBTIGER” Ltd.:
erase, rectify, or block personal data whose processing does not comply with legal requirements;
notify third parties to whom the data have been disclosed of any erasure, rectification, or blocking, unless this proves impossible or involves disproportionate effort.
Requests for access or rectification may be submitted electronically via email to:
data_protection@jobtiger.bg.
“JOBTIGER” Ltd. responds to such requests within 30 days of receipt. Where objectively necessary, this period may be extended to 90 days, with timely notification and a reasoned response to the data subject.
Notification of recipients in case of rectification, erasure or restriction
Where “JOBTIGER” Ltd. has carried out rectification, erasure or restriction of processing of personal data at the request of the data subject, it shall notify all recipients to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. Upon request, “JOBTIGER” Ltd. shall provide the data subject with information about such recipients.
Right to Object
At any time, the data subject has the right to object to the processing of their personal data where lawful grounds exist. Where the objection is justified, the personal data of the respective individual shall no longer be processed.
Right to Restriction of Processing
The data subject has the right to request restriction of processing where:
the accuracy of the personal data is contested, for a period enabling verification;
the processing is unlawful and the data subject requests restriction instead of erasure;
“JOBTIGER” Ltd. no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise, or defence of legal claims;
the data subject has objected to processing and verification is pending as to whether the controller’s legitimate grounds override those of the data subject.
Right to Data Portability
The data subject has the right to request that “JOBTIGER” Ltd. provide their personal data in a structured, commonly used, and machine-readable format where:
processing is based on consent or on a contract; and
processing is carried out by automated means.
Right to Lodge a Complaint
Where the data subject considers that “JOBTIGER” Ltd. infringes applicable data protection legislation, they have the right:
to contact the company for clarification; and/or
to lodge a complaint with the competent supervisory authority – the Commission for Personal Data Protection.
As of 25 May 2018, a complaint may also be lodged with a supervisory authority in another EU Member State.
Where to Address Requests When Applying for a Job
If your request (e.g. access, rectification, erasure, objection) relates to a specific job application, the relevant employer acts as the data controller and the request should be addressed directly to that employer.
“JOBTIGER” Ltd. may assist by forwarding the request to the employer and/or implementing the requested action within the platform, insofar as it processes the data on behalf of the employer.
If your request relates to your JobTiger.bg account, newsletters, notifications, access security, or other processing activities for which “JOBTIGER” Ltd. acts as data controller, you may exercise your rights via email at: data_protection@jobtiger.bg
Right of Access
The data subject has the right to obtain confirmation at any time as to whether personal data concerning them are being processed and, where that is the case, access to such data and information about the processing and their related rights.
Objection to processing for direct marketing purposes
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to such processing. Upon receipt of an objection, the personal data shall no longer be processed for direct marketing purposes as of the time of the objection.
Automated decision-making and profiling
JobTiger does not carry out automated decision-making, including profiling, within the meaning of Article 22 of Regulation (EU) 2016/679, which produces legal effects concerning data subjects or similarly significantly affects them.
Right to Erasure (“Right to Be Forgotten”)
The data subject has the right to request the erasure of personal data relating to them without undue delay where the grounds set out in Article 17 of Regulation (EU) 2016/679 apply.
