Politica de confidențialitate

Politica de Confidențialitate

1. Who Processes Your Personal Data

The data controller for the activities described in this policy is "Jobche" EOOD, UIC 208901386, with registered seat and management address: Sofia, postal code 1715, Mladost district, Mladost 4 residential complex, Filip Avramov Str., bl. 411, entrance 5, floor 3, apt. 9, represented by Martin Viktorio Pavlov.

Privacy contact: martin@jobche.eu Phone: +359 8888 955 35

2. Who This Policy Applies To

This policy applies to:

visitors to Jobche.eu;
individuals who create a candidate profile, upload a CV, save listings, receive notifications, or submit an application;
legal representatives, employees, and other authorized persons of Employers;
persons who submit a report, inquiry, complaint, or request regarding personal data;
other persons whose data is lawfully included in submitted content.

3. Jobche's Role in the Application Process

3.1. Jobche is an electronic platform that allows the Candidate, at their own discretion, to submit an application to a specific listing and a specific Employer. When applying through Jobche, the Platform technically receives, stores, and transmits the data and documents chosen by the Candidate to the designated Employer.

3.2. Jobche does not evaluate, rank, recommend, or perform selection of Candidates. The recipient of the application is determined by the Candidate themselves through the act of applying.

3.3. Once the specific Employer receives the application, it is generally an independent controller for its own purposes of selection, communication, interviewing, evaluation, checks, and possible hiring. The Employer should independently provide information about its own processing and ensure the exercise of the Candidate's rights.

3.4. When Jobche provides an employer panel and performs limited technical operations with applications entirely on the Employer's instructions, for this limited scope Jobche may act as a processor. These relationships are governed by the applicable contractual terms and, where necessary, by an agreement under Art. 28 GDPR.

3.5. When a listing directs to an external site, the application is submitted directly in the system of the respective Employer or its provider. In this case, their terms and privacy information apply.

4. What Categories of Personal Data We Process

4.1. Visitors

We may process the device's internet address, date and time, browser and device, pages visited, technical events, security data, source of the visit, and cookie choices.

4.2. Candidates

Depending on the features used, we may process:

name, email, phone, and login data;
location and professional preferences;
education, qualifications, professional experience, skills, languages, and other information the Candidate chooses to include;
CV, cover letter, portfolio, and other attached files;
saved listings and notification criteria;
the listing, Employer, date, and content of a specific application submitted;
history of material actions in the profile;
communication with support;
evidence of acceptance of terms, settings, and consents.

4.3. Employers and Their Representatives

We may process:

company name, UIC or other registration number, address, country, website, and sector;
name, position, official email, and phone of the representative;
login data and access rights;
information and documents for verifying the company and representative authority, where necessary;
listings, company description, logo, and edit history;
applications and actions in the employer panel;
plan, order, billing data, identifiers, and payment status;
correspondence, reports, and decisions regarding the account.

4.4. Inquiries, Reports, and Exercise of Rights

We process contact details, the content of the request or report, attached evidence, the affected listing/account, correspondence, actions taken, and evidence of fulfillment.

5. Data You Should Not Provide Unless Necessary

Jobche does not require special categories of personal data or data on criminal convictions and offenses for general registration. Do not include in free-text fields or your CV a national ID number, ID card number and copy, bank details, health information, religious or political beliefs, trade union membership, biometric data, data on sex life, or convictions, unless this is expressly necessary for a specific lawful purpose and you have received clear instructions.

Upon identifying clearly excessive or risky data, Jobche may restrict access to the file, request a replacement, or take another proportionate action to protect the individual and the system.

6. Purposes and Legal Basis for Processing

Activity	Main purpose	Legal basis
Creating and managing a candidate profile	providing requested features, login, and settings	performance of a contract/actions requested by the individual; legitimate interest in security
Storing a CV in the profile	convenience for future applications and management by the Candidate	performance of the requested service
Technical transmission of a specific application	sending data to the Employer chosen by the Candidate	performance of an action explicitly requested by the Candidate and provision of the service
Saved listings and settings	provision of personal features	performance of the requested service
Notifications about new positions	sending based on criteria chosen by the user	consent, where required; explicitly requested electronic service
Employer account	creation and management of access to paid features	contract/pre-contractual actions
Employer account verification	identification, prevention of fraud and abuse	contract and legitimate interest in security and user protection
Publishing and moderating content	providing the platform, safety, and fulfillment of legal obligations	contract; legal obligation; legitimate interest
Payment and invoicing	fulfilling the order, accounting, and tax reporting	contract and legal obligation
Security and abuse prevention	protecting accounts, systems, data, and rights	legitimate interest; applicable legal obligations
Responding to requests and complaints	exercising rights, resolving cases, and evidencing	legal obligation; contract; legitimate interest
Establishing and defending legal claims	protecting the rights of Jobche and third parties	legitimate interest and applicable law
Optional cookies and similar technologies	functionality, statistics, or advertising depending on the category	prior consent, where required

When we rely on legitimate interest, we assess the necessity of the processing, the reasonable expectations of individuals, and the possible impact on their rights and freedoms. Where a right to object exists, it may be exercised as described below.

7. Which Data Are Mandatory

Only data without which the respective requested feature, verification, order, or legal obligation cannot be fulfilled is mandatory. Failure to provide it may prevent registration, applying, employer account verification, or purchase.

Notifications about new positions and optional cookies are voluntary. Declining them does not limit basic browsing of listings or the ability to apply.

8. Where We Get the Data From

We receive data:

directly from you;
from the organization you represent;
from public official registers when verifying an employer account;
from the payment provider regarding the status and identifiers of the payment;
from providers of technical infrastructure, security, and electronic communications;
from persons who submit a report or complaint;
from a public or contracted source of listings, where such functionality is used and there is a basis for it;
from competent authorities, when the law allows or requires this.

9. Who We May Share Data With

9.1. The Employer Chosen by the Candidate

When applying through Jobche, the data and documents specified immediately before sending are provided to the specific Employer whose listing the Candidate has chosen to apply to. Jobche does not determine the recipient on behalf of the Candidate and does not distribute the CV to other Employers without a separate action or another valid basis.

9.2. Technical Service Providers

We may use external providers for:

hosting, databases, and core software infrastructure;
file storage, backups, and recovery;
email and notifications;
information security, monitoring, and technical support;
cookie management and statistics, if enabled;
payment services.

These providers receive only the necessary access and are contractually bound according to their applicable role. Their current list is maintained internally and reviewed upon change.

9.3. Stripe

Card payments are processed via Stripe. Payment card data is entered into Stripe's secure payment environment. Jobche should not store the full card number or security code. For certain of its own payment, regulatory, and protective activities, Stripe may act as an independent controller.

9.4. Professional Advisors and Competent Authorities

Data may be provided to accountants, lawyers, auditors, banks, insurers, courts, police, the National Revenue Agency, the Commission for Personal Data Protection, the Communications Regulation Commission, or another competent authority, where there is a legal basis.

10. Transfer of Data Outside the European Economic Area

Some of the technical or payment providers used and their subcontractors may process data outside the European Economic Area.

Where applicable, the transfer is carried out under an appropriate legal mechanism, for example a European Commission adequacy decision, standard contractual clauses, additional technical and organizational measures following an assessment of the transfer, or another basis permitted by the GDPR.

Information about the applicable safeguards may be requested at martin@jobche.eu, though parts protected due to security or trade secrets may be limited.

11. How Long We Retain the Data

We apply retention periods aligned with the purpose, contractual relationships, legal obligations, and the need to protect rights. The main periods are:

Category	Main period/criterion
Candidate profile	until terminated by the Candidate; in the event of prolonged inactivity, may be closed after 12 months without activity and a prior 30-day warning
CV in the profile	until replaced, deleted by the Candidate, or the profile is closed, unless there is a basis for temporary limited retention
Application in Jobche's system	up to 12 months from submission, unless a shorter period is technically configured or a longer period is necessary for a specific dispute/legal obligation
Notifications and settings	until unsubscribed/deleted; limited evidence of settings may be kept for up to 24 months or for the necessary protective period
Employer account, listings, and related decisions	for the duration of the relationship and up to 5 years after termination, where necessary for the protection of rights and accountability
Orders, invoices, and accounting documents	for the applicable accounting and tax period, which for some documents may reach 10 years
Correspondence, reports, and complaints	generally up to 3 years; up to 5 years in the event of a dispute, a decision on content, or the need for evidence
Technical security logs	generally up to 90 days; longer only for a specific incident or a justified protective need

After the applicable period expires, the data is deleted, anonymized, or separated under a restricted regime, where retention is necessary by law or for a specific legal claim.

12. Automated Decisions and Selection

Jobche does not make hiring decisions and does not perform automated selection with legal or similarly significant effects on the Candidate.

Search, filtering, sorting, and notifications may use parameters of the listings and criteria set by the user. They serve the technical organization of content and do not constitute an evaluation, ranking, or recommendation of a Candidate to an Employer.

Before introducing functionality for suitability assessment, automated matching, pre-selection, or automated rejection, a separate legal and technical review will be carried out, including an assessment of risks to personal data and discrimination, where necessary.

13. How We Protect the Data

We apply and require appropriate measures from providers according to the risk, including:

encrypted transmission and appropriate protection at rest;
individual profiles and role-based access control;
multi-factor authentication for administrative accounts, where technically available;
logging of administrative and risk-related actions;
protection of uploaded files and limited access links;
backups, vulnerability management, and recovery procedures;
contractual confidentiality obligations and provider audits;
security breach procedures and timely access revocation.

14. Your Rights

Under the GDPR, you have the right to:

information and access to your personal data;
correction of inaccurate or incomplete data;
erasure, where the legal preconditions are met;
restriction of processing;
data portability, where applicable;
object to processing based on legitimate interest;
object at any time to direct marketing;
withdraw consent for future processing, where the basis is consent;
protection in relation to certain solely automated decisions, where applicable;
lodge a complaint with the competent supervisory authority and seek judicial protection.

These rights are not absolute and may be limited on legal grounds, for example to protect the rights of other persons, fulfill a legal obligation, or establish and defend legal claims.

15. How to Exercise a Right

Send a request to martin@jobche.eu, providing sufficient information for us to determine which profile or processing the request concerns.

In case of reasonable doubt about identity, we may request additional verification. Do not send a copy of an ID card unless expressly requested and there is no less intrusive way to verify.

We respond without undue delay and generally within one month. In case of complexity or multiple requests, the period may be extended by up to two additional months, of which you will be notified within the initial period.

16. Rights Regarding the Employer

After receiving the application, the Employer may store a copy or process the data in its own systems as an independent controller. A request for deletion or another change in these systems should also be directed to the respective Employer.

Jobche will assist to a reasonable extent when the request concerns features it controls, but cannot erase data from a system controlled independently by the Employer.

17. Complaint to a Supervisory Authority

You have the right to lodge a complaint with the Commission for Personal Data Protection, as well as with another competent supervisory authority under the GDPR. This right is not conditional on a prior complaint to Jobche.

18. Persons Under 18

The Platform is not intended for independent creation of a candidate account by persons under 18. If we learn that a profile has been created in violation of this rule, we may restrict or terminate the profile and take the necessary actions regarding the data.

19. Cookies and Similar Technologies

Detailed information is contained in the Cookie Policy. Optional technologies are activated only after a valid choice, where the law requires this. Settings can be changed via the permanent "Manage Cookies" link.

20. Changes to the Policy

We may update the policy in the event of a change to the services, providers, technologies, or legal framework. The date of the last update is indicated at the beginning. In the event of a material change, we will provide appropriate additional notice, where necessary.

Information about a previous version may be requested at martin@jobche.eu.

21. Contact

"Jobche" EOOD UIC 208901386 Address: Sofia, postal code 1715, Mladost district, Mladost 4 residential complex, Filip Avramov Str., bl. 411, entrance 5, floor 3, apt. 9 Email: martin@jobche.eu Phone: +359 8888 955 35