Privacy Policy
Kumans Ltd. strictly complies with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and the Personal Data Protection Act (PDPA) and has appointed data protection officers within the company.
All our employees have signed declarations committing to comply with regulatory requirements and internal rules for the protection, security, and confidentiality of personal data.
Administrator details:
Kumans Ltd. is a licensed company in the field of providing human resources management services.
Contact details:
- Sofia, 1138, Gorublyane district, 8, Deyan Popov str,
- info@kumans.eu
- +359 895 795 152
Data Protection Officer:
You can contact the Data Protection Officer at the following email address:
- info@kumans.eu
This policy covers the personal information we process in connection with:
- use of our website, responses to service requests
- the provision of services and products
- all other cases in which we collect and use personal data.
This Policy may sometimes be supplemented by separate privacy notices relating to specific services, tools, applications, websites, portals, marketing initiatives, sponsored social networks, etc., which are provided and/or operated by us or on our behalf. You will be individually informed when we process personal data based on these specific notices.
In the processes of Kumans EOOD's activities, we may collect the following personal data:
| User type | When do we collect personal information? | Goal / Activity | Information type | Legal basis for processing | Shelf life |
| Visitors to the website kumans.eu. | When visiting the website and performing actions on it | .To respond to your inquiries and improve site management Information | that you voluntarily provide to us when contacting us via the form | Steps before entering into a contract at your request. Legitimate interest in improving our website and services | 3 years |
| Candidates to whom Kumans Ltd. provides mediation services | When applying through the platforms jobs.bg, zaplata.bg, rabota.bg | To provide an intermediary service – finding a job | Name, email, phone, date of birth, citizenship, work permit | Steps before concluding a contract; execution of an intermediary contract | 6 months after completion of the selection, with consent – up to 3 years |
| Candidates recommended by business partners | Through social networks and the website kumans.eu | – | Data on education, work experience, language skills, recommendations, career preferences | Fulfillment of regulatory obligations under the Regulation on Intermediary Activities | – |
| Candidates hired under an employment contract by Kumans Ltd. for temporary employment | When signing an employment contract and secondment | For the fulfillment of the obligations of a temporary employment agency | Name, personal identification number, date of birth, citizenship, medical documents, criminal record, bank account | Steps before concluding a contract | 50 years |
| Job applicants at Kumans Ltd. | When applying for an advertised position in the company. | Selection of the most suitable candidate | . Education, qualifications, work experience, language skills, recommendations, other data at the discretion of the candidate | Legitimate interest. Upon approval – processing for the purpose of entering into a contract | 6 months, with consent – up to 3 years |
| Recipients of direct marketing | When subscribing to a newsletter or marketing messages | Sending news and marketing content | Name and email address | Consent | Until consent is withdrawn |
Data acquired from external (third) sources
- We collect information from your logins to our Internet service provider's servers, including information about your computer, IP address, operating system, and browser type (referred to as "usage data"). This information is used for system administration and analysis of website usage. The legal basis for processing this information is our legitimate interest in monitoring, analyzing, and managing the content of the site in order to improve our products and services.
- We additionally collect personal data from our social media pages, including likes, shares, posts and tweets. The legal basis for the processing is our legitimate interest in monitoring and analyzing our presence on social media, as well as developing and improving our services. Please note that social media have their own terms of use, which you should read separately. You should also be aware that postings on social media may affect the privacy of your personal data or the data of others that you share. You are fully responsible for your postings and shared information on social media. We do not assume any liability for these postings and information.
- We also collect personal information from other publicly available and reliable sources, such as the Commercial Register, LinkedIn.com, Facebook.com, job posting platforms and similar sites. The legal basis for processing this information is our legitimate interest in developing and improving our recruitment services at various levels and reaching a wide audience of potential candidates.
- We use cookies or similar technologies that are stored on your device to track how you use our website. Cookies contain information that is transferred to your computer's hard drive. They help us improve our website and provide you with better and more personalized services. Our Cookie Policy is available here: https://kumans.eu/cookie-policy/
Related platforms
Our websites may contain links to and from other websites and digital platforms operated by our affiliate networks, partners and advertising agencies. It is important to note that these websites are operated by third parties and have their own privacy policies. We are not responsible for the way they process your personal data. We recommend that you familiarize yourself with the privacy policies of these external sites.
Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The information collected by cookies about your use of the website is usually transmitted to a Google server in the USA and stored there.
Our website uses Google Analytics with the “IP anonymization” extension. This means that within member states of the European Union or other countries that are parties to the Agreement on the European Economic Area, your IP address collected by the Google Analytics cookie will be shortened by Google before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the company, Google uses this information to evaluate your use of the website, compile reports on website activity and provide the website operator with additional services relating to website and internet use. The IP address sent by your browser within the framework of Google Analytics will not be merged with other Google data.
You can prevent the storage of cookies by configuring your browser accordingly; please note that in this case you may not be able to use all the functions of our website. You can also prevent the collection and processing of data collected via cookies and related to your use of the site (including your IP address) by downloading and installing the browser add-on from the following link:
https://tools.google.com/dlpage/gaoptout?hl=bg
Detailed information about the terms of use and data protection can be found at:
https://www.google.com/analytics/terms/bg.html
or at:
https://support.google.com/analytics/answer/6004245?hl=bg
The legal basis for processing personal data when using cookies is Art. 6, para. 1, letter “e” of the GDPR.
Use of Google Inc.’s “remarketing” or “similar audiences” service.
On our website we use Google’s “Remarketing” or “Similar Audiences” function. With the help of this function we can show you targeted advertising tailored to your interests when you visit other websites in the Google Display and/or Search Network. Google uses so-called cookies to analyze the use of the site, which is the basis for creating interest-based ads. For this purpose, Google saves a small file with a numerical sequence in the visitor’s browser. This number is used to register visits to the site, as well as anonymized data on the use of the site. No personal data of the visitors is stored. If you subsequently visit another site in the Google Display Network, you will be shown a corresponding advertising message, which is most likely related to products and sections that you have already visited.
Additional information about Google Remarketing, as well as Google’s privacy policy, can be found here:
https://policies.google.com/technologies/ads
You can permanently disable Google’s use of cookies by following this link and downloading the plugin provided there:
https://support.google.com/ads/answer/7395996
Alternatively, you can disable the use of third-party cookies via the Network Advertising Initiative page:
http://optout.networkadvertising.org/?c=1#!/
The legal basis for the processing of personal data when using cookies is Article 6, paragraph 1, letter “f” of the GDPR.
Social networks and social plugins
Through our social media pages, we offer you personalized and comprehensive support. If you send us a request through one of these social networks, we will redirect it to the relevant department. The data is used solely for the purpose of responding to your request and is not provided to third parties. The legal basis for the processing of personal data in connection with the processing of your request is Art. 6, para. 1, b. “e” of the GDPR.
In order to contact us via social networks, you must be registered on the respective platform. For this purpose, the companies that manage them process personal data to a volume determined by them. We have no influence on the type, scope and manner of processing this data.
Our website uses social plugins from the social network Facebook. The controller of the personal data of users in the EU is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and the operator is Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). More information about Facebook plugins and their appearance can be found here: https://developers.facebook.com/docs/plugins.
When you open a page of our website that contains such a plug-in, your browser establishes a direct connection to the Facebook servers. The plug-ins transmit their content directly from Facebook to your browser and integrate it into the web page. Through this integration, Facebook receives information that your browser has loaded the corresponding page of our website – even if you do not have a Facebook account or are not logged in. This information (including your IP address) is transmitted from your browser directly to a Facebook server in the USA and stored there.
If you are logged in to Facebook, Facebook can directly associate your visit to our website with your profile. If you interact with the plug-ins – for example, leave a comment – this information is also transmitted directly to a Facebook server and stored. It is also published on your profile and visible to your Facebook friends.
Please note that as the provider of the website, we do not receive any information about the content of the transmitted data or its subsequent use by Facebook. For more information about the purpose and scope of data collection, its further processing and use by Facebook, as well as your rights and settings to protect your privacy, please visit Facebook’s privacy policy: https://www.facebook.com/policy.php.
If you do not want Facebook to link the data collected through our site directly to your Facebook profile, you must log out of Facebook before visiting our site.
To the extent that the data described above constitute personal information, the legal basis for their processing is Art. 6, para. 1, b. “f” of the GDPR.
Processing of collected personal data
Kumans Ltd. uses the information described above to carry out the following activities:
- Offering corporate solutions for personnel selection, representation and mediation between employers and candidates.
- Notification of available positions and active interaction with professionals.
- Monitoring, analyzing and improving our operational processes.
- Protection from fraud and illegal activities.
- Fulfillment of additional contractual and legal obligations.
- Ensuring compliance with and implementation of applicable legal requirements, industry standards, contractual commitments and internal procedures.
In addition to the activities described above, Kumans Ltd. may use the data provided by job applicants when:
- Offers job opportunities and specific employment offers.
- Provides additional services such as training, career guidance and professional development.
- Assesses the professional suitability and qualifications of candidates for specific positions.
- Performs in-depth analysis using available data sources, including candidate databases, individual performance evaluations, project duration, identification of skills gaps, analysis of recruitment channels, trends and selection practices.
Disclosure of your personal data
Kumans Ltd. strictly observes the confidentiality of the collected personal data and refrains from public or unauthorized disclosure, except in the cases specified in this Privacy Policy.
Your personal data may be shared in the following ways:
- To our clients: We provide a limited amount of personal data to clients interested in providing suitable job opportunities or entering into contractual relationships with our candidates.
- Service providers: In rare cases, we may share your personal data with external service providers that are essential to the operations of Cumans Ltd. These providers are contractually bound to maintain the confidentiality and security of the data received and to use it only in accordance with our instructions.
- Public authorities: We may be required to disclose or provide your personal data in order to comply with legal requirements, enforce contract provisions, or protect the rights, property, and safety of our company, customers, and others.
- Other circumstances: In the event of a sale of a business or transfer of assets, your personal data may be disclosed to potential buyers of the relevant operations or assets.
Transmission of personal data
If the provision of our services requires the transfer of personal data to recipients outside the European Economic Area (EEA), Kumans Ltd. will carry out this transfer in accordance with the requirements of the General Data Protection Regulation (GDPR). We ensure that appropriate measures – such as standard contractual clauses – are in place to ensure the necessary level of protection.
While we are committed to the security of your personal data, it is important to note that data transmission over the Internet is not completely risk-free. In cooperation with our service providers, we make all reasonable efforts to protect your data. However, the decision to provide us with personal information remains entirely yours and is made at your own discretion and risk.
Security of personal data
Kumans Ltd. has implemented and applies adequate administrative, technical and physical measures to prevent breaches of information security and protect the processed personal data from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Our employees who have access to personal data receive training in working with sensitive information and are bound by contractual obligations to treat this information confidentially.
Our security protocols include encryption of all dynamic and static company information, as well as implementing a “complete forget” method in the recruitment software we use.
Your rights:
- Right to Information: You have the right to be informed about how we collect and process your personal data, including information about our identity, how we use your information and what your rights are in relation to this, as set out in this Privacy Policy.
- Right to access your personal information: You have the right to access the personal data we hold about you. We can
- Right to correct your data: If your personal data is inaccurate or incomplete, you have the right to request its correction and updating by contacting us.
- Right to erasure of your personal information: You can request the erasure or removal of your personal data if there is no legitimate reason for us to continue processing it. You have the right to be “completely forgotten” when the data is no longer necessary for the original purpose of its collection or processing and when you have withdrawn your consent to its processing.
- Right to restriction of processing: In certain circumstances, such as where a dispute arises regarding the accuracy of the data, you have the right to request that the processing of your personal data be suspended until the dispute is resolved.
- Right to data portability: If we process your personal data based on your consent or in connection with a contract, you have the right to receive your data in a commonly used, structured and machine-readable format and to transmit it to a third party of your choice.
- Right to object: You have the right to request that we not process your personal data for the purposes of our legitimate interests, including for marketing purposes. We will usually inform you in advance (before collecting your personal data) if we intend to use it for such purposes or disclose it to a third party for that purpose. You can exercise this right by indicating your preferences in the forms we use to collect personal data. You can also contact us at any time at privacy@kumans.eu.
- Withdrawing consent: Where we process your personal data based on your consent, you have the right to withdraw that consent at any time.
For further information regarding the protection of your privacy rights, you can contact the Personal Data Protection Commission at: https://www.cpdp.bg/.
If you have any questions or complaints
For additional information regarding the personal data we process or if you have any complaints, you can contact us in the following ways:
By email: info@kumans.eu
By letter to the address: 8, Deyan Popov Str., Gorublyane District, 1138 Sofia, Bulgaria
We will try to answer your inquiries as quickly as possible.
You also have the right to file a complaint with the Commission for Personal Data Protection. More information can be found at: https://www.cpdp.bg/.
Privacy Policy Changes
This Privacy Policy is subject to periodic changes and updates to reflect any changes in our privacy practices.
We will notify you of any changes to the Privacy Policy in an appropriate manner – through a visible notice on our website, by email, or through another communication channel of your choice.
