Data Protection
GENERAL PERSONAL DATA PROTECTION POLICY OF “Upskill” LLC
Effective from: May 2018
This General Policy explains how we collect and process your data in our capacity as a Data Controller.
YOUR RESPONSIBILITIES
• Familiarize yourself with this General Policy.
• If you are in a contractual relationship with us, please check the related terms and/or policies—they may contain additional details about how we collect and process your data.
• Pay attention to any additional information and conditions we provide at different stages of our interaction.
• If you provide us with personal data about other people, or if others provide us with your information, we will use this data only for the specific purpose for which it was provided. If you provide information about third parties, you must have a legal basis to do so and must also inform those third parties about how we will process their data.
• By providing us with data, you declare that you are over 18 years of age.
We, “Upskill” LLC, are the Data Controller responsible for your personal data. Our main business activity is in the field of EMPLOYMENT. Due to the specifics of this activity, we have developed the following separate policies:
(a) Personal Data Protection Policy – employment and recruitment services
(b) Personal Data Protection Policy for employees working under temporary employment
Please review them if you use our employment services.
If you have questions about any of our Policies or your personal data, please contact us.
Contact details:
“Upskill” LLC, UIC: 203043788
Registered address: Sofia, Bulgaria Blvd. 111A, 4th floor
Email: office@upskill.bg
We have appointed a Data Protection Officer. Contact: dpo@upskill.bg
It is very important that the information we have about you is accurate and up to date. Please inform us of any changes or if you notice errors.
We process personal data for specific purposes and on legal grounds depending on your role in relation to us.
A) Automatically collected information:
You may access the website without providing personal data. However, certain information is processed automatically, such as log files, cookies, and website analytics (Google Analytics).
B) Social plug-ins (Facebook, Twitter, LinkedIn, etc.)
Use of these plug-ins is voluntary. They link to third-party sites that collect and process personal data according to their own policies. We are not responsible for them and recommend reviewing those policies.
We use these plug-ins to improve website functionality and promote our services, which we consider our legitimate interest.
C) Links to other websites:
Our site may link to other sites. If you follow such links, please review the respective privacy policies.
D) Personal data you provide through the website:
When you use our contact form or another service, we process your data for the purpose for which you provided it. Required fields contain the minimum necessary data. Please do not submit unnecessary personal information.
Sometimes processing is based on pre-contractual grounds—when you request to enter into a contract with us. If you apply for employment with us, please see section 3.9.
E) Sensitive data:
We do not collect sensitive data (race, religion, health data, etc.). Please do not provide such data.
F) Data combination:
Sometimes we combine website data with data obtained via email, phone, public registers, rating companies, partners, etc. We do not use combined data for other, undisclosed purposes.
We may request your name, the organization you represent, the date/time of your visit, and the employees you meet. This is our legitimate interest for access control and internal activity tracking.
We collect data required for your participation. Events may be photographed or recorded. We may use images to promote the event unless you request otherwise.
We may also contact you about future events or ask for feedback.
We process the information you provide for the purpose of the campaign.
We may respond to your inquiries or contact you if you request it.
We collect registration data, performance data, test results, etc. We may contact you about future trainings.
We collect your contact details, role, communication history, signatures, and any necessary information for our business relations.
We may obtain your data from public sources, referrals, events, etc. We may contact you based on legitimate interest. You may object at any time.
We process your CV, motivation letter, interview information, tests, and references.
If you are not selected, we delete your data within one week (or up to two months after a closing date).
If we want to keep your data for future opportunities, we will request your consent.
If you apply without a specific position, we may store your data for up to three years based on legitimate interest.
• internal administration and reporting
• fraud prevention
• establishing and defending legal claims
• performing contractual obligations
• compliance with legal obligations
• service effectiveness analysis
• Legal obligation
• Legitimate interest
• Contractual or pre-contractual necessity
• Your consent (which you may withdraw at any time)
If a legal or contractual obligation applies, refusal may prevent us from fulfilling the agreement or achieving the purpose.
• Related companies
• Service providers (hosting, IT, couriers, etc.)
• Other controllers (banks, auditors, lawyers, insurers)
• Public authorities
• Third parties in case of business transfers or mergers
Data is usually processed within the EU/EEA.
Transfers to third countries are allowed only with adequate safeguards (e.g., EU Commission adequacy decision, Standard Contractual Clauses, or EU-US Privacy Shield).
We apply security measures to prevent unauthorized access, loss, or misuse. Access is granted only to those who need it.
We store your data only as long as necessary.
Tax laws require us to store certain information for five years plus the current year.
We follow applicable limitation periods for legal claims.
Data may be anonymized for research or statistical purposes.
You have the right to:
• access your data
• request correction
• request deletion
• object to processing (including direct marketing)
• request restriction of processing
• data portability
• withdraw consent
To exercise your rights, email us at s.ivanov@upskill.bg or write to our address.
We may request identity verification.
We aim to respond within one month.
You may file a complaint with the Bulgarian Commission for Personal Data Protection:
Address: Sofia 1592, Prof. Tsvetan Lazarov Blvd. 2
Email: kzld@cpdp.bg
Website: www.cpdp.bg
We kindly ask you to contact us first so we can try to resolve the issue.
We may update this Policy and will publish changes on www.upskill.bg. For significant changes, we will notify you via email or another appropriate method.
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