Privacy Policy

Dear ladies and gentlemen,

Please, read the following information carefully to learn details about your personal data processing in the capacity of consulted specialist, potential employer or other interested party.

The Information could be updated and the amendments will enter into force after publication of the following Information for personal data processing.

Effective from August 2020.

1. The company

IT PROvocator Ltd. is a company established in accordance with the laws of the Republic of Bulgaria, registered in the Commercial Register at the Registry Agency under Unified Identification Code (UIC) 204427546 with registered office and address of management in Sofia, 1 Daskal Manol Str., Entrance D, fl. .4, ap. 60 (‘the Company’).
IT PROvocator Ltd. provides business consultations to potential employers for the territory of Bulgaria, as well as consultations to professionals in the information and communication technologies sector in connection with their professional development and career goals. Our service consists of career counseling of these specialists and support of the interaction between them and the potential employers.
2. Contact details
If you have any questions regarding the processing of personal data, please contact us at: provocator@itprovocator.com or phone +359 878 354660
3. Types of processed personal data:
The company may process various types of personal data related to the physical identity, social identity or economic identity of the data subjects. The data may be obtained from the data subject, from third parties or may be created by the Company during the relationship with the personal data subject.
3.1. The company may process different types of data depending on the purpose of the processing, for example:
a. to identify you: name, address
b. to contact you: phone number, email
c. in addition to the above personal data, the Company also processes additional information for consulted specialists such as: education, qualification, work experience,

3.2. Public data and data obtained from third parties
The company sometimes processes public data. The company may also receive personal data through third parties, for example through official registers, which are responsible for collecting this information.
4. Recipients of personal data
Personal data 
is processed mainly by employees of the Company in the minimum amount necessary to perform their duties. The processing of personal data may also be performed by other persons in connection with the services provided to the Company on the basis of a contract for personal data processing concluded with the Company.
a. Recipients of personal data to whom the Company may transfer personal data include:
CPDP (Commission for Personal Data Protection)
CPC (Consumer Protection Commission)
Other officials
b. The persons to whom personal data is transferred for processing are natural or legal persons, public authorities, agencies or any other competent authority.
c. Recipients outside the European Economic Area (EEA)
Some of the above recipients may be located outside the EEA. The Company will transfer personal data to non-EEA countries (third countries) only if the necessary safeguards are in place to protect personal data in accordance with local and European legislation and the personal data provided 
is adequately protected in the third country concerned.

5. Duration of personal data storage
The Company stores the personal data of the data subjects in accordance with the statutory retention periods, and when there are none, the personal data will be deleted within five (5) years after the termination of the relationship with the data subject, unless in order to protect and from legal claims imposes a longer term for processing, in view of the expiration of the statute of limitations determined by law.
6. Purposes of personal data processing
The personal data collected by the Company may be processed for different purposes and on different legal grounds, as follows:
6.1. Objectives for which the processing of personal data is necessary for the performance of a contract:
a. Conclusion, amendment or termination of contracts and fulfillment of contractual obligations by the Company – for example, service contracts.
6.2.
 Providing information and counseling in the field of career development and supporting the interaction between potential employers and employees.
7. Data Subjects Rights
All data subjects have the following 
personal data processing rights and may exercise any of them at their discretion and in the presence of the relevant legal prerequisites:
a. Right of access – At the request of the Data Subject, the Company provides information on the categories of personal data related to it that are collected and processed, as well as information on the purposes of processing, recipients or categories of recipients to whom the data is disclosed and the sources of such data.
b. Right to correct, delete and limit the data processing in cases where the processing does not comply with the provisions of the law – At the request of the Data Subject, the Company will correct (for example, when the data is inaccurate or incomplete), delete (for example, when the data is not needed more for the purposes for which they were processed or the data subject withdraws his consent) or limit the processing of personal data (for example if the accuracy of personal data is contested for the period of accuracy or the company no longer needs them, but the data subject requests them for the establishment, exercise or defense of legal claims or the data subject has objected to the processing – while the relevant verification is in progress). The company will not delete personal data if they are necessary to comply with a legal obligation, to perform a task of public interest or in other cases provided by law.

c. Right to data portability – The data subject has the right to receive his personal data, which he has provided to the Company, in a publicly accessible, structured and machine-readable format and has the right to transfer these data to another Administrator when the processing of personal data based on consent or contractual obligation or the processing of personal data is carried out in an automated manner.

d. Right to object – The data subject has the right to object against the processing of his or her personal data when:

  • the processing of personal data is based on the performance of a task of public interest or the legitimate interest of the controller. In this case, after considering the objection, the Company terminates the processing of personal data of the individual unless there are legal grounds for the Company to continue processing (for example for the purposes of establishing, exercising or protecting legal claims. will inform the Data Subject who has filed the objection in order to clarify to him the reasons of the Company to continue the processing of his personal data.

  • the processing of personal data is for the purposes of direct marketing, incl. and profiling for direct marketing purposes;

e. Right to claim before the Commission for Personal Data Protection (CPDP) – The data subject has the right to file a complaint to the Commission for Personal Data Protection (CPDP) against illegal actions of the Company in connection with the processing of his personal data ( www.cpdp.bg, tel. 02/9153518, Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.).