Privacy Policy

Who We Are

This Privacy Policy explains how we collect, use, store, and protect the personal data of job applicants, visitors to our websites, individuals who contact us, and representatives of our clients, business partners, and suppliers.

ASTREA RECRUITMENT Ltd. is a licensed employment agency registered pursuant to Article 5(1) of the Ordinance on the Terms and Procedure for Carrying Out Employment Mediation Activities, holding Registration Certificate No. 1809 / 18 June 2025, issued by the Bulgarian Employment Agency.

Our mission is to connect businesses with talented professionals by providing the best employment opportunities while meeting the recruitment needs of our clients.

In order to carry out our core business activities — recruitment and career consulting — as well as to comply with our statutory obligations towards the Bulgarian Employment Agency regarding the administration and supervision of employment mediation activities, we collect, store, and process candidates' personal data while ensuring:

• that your personal data is used solely for recruitment and career consulting purposes;
• the confidentiality, integrity, availability, and accuracy of your personal data through appropriate technical solutions, organisational measures, and internal control procedures;
• transparent procedures enabling you to exercise your rights under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation" or "GDPR");
• dedicated career consultants who can provide you with suitable job opportunities, guidance throughout the recruitment process, and assistance in exercising your data protection rights.

Our commitment is to provide professional recruitment and career consulting services while implementing appropriate technical and organisational measures to protect personal data in accordance with the GDPR and all applicable legislation.

Legal Bases for Processing

ASTREA RECRUITMENT Ltd. collects and processes personal data lawfully, fairly, and transparently, in accordance with the principles established by Regulation (EU) 2016/679 (GDPR) and the applicable Bulgarian legislation. We process your personal data only where a valid legal basis exists.

1. Performance of a contract or steps prior to entering into a contract

This legal basis applies when we contact you regarding your successful application for a job vacancy. In order to assist you in applying for employment with a current or prospective employer, we are required to conclude an Employment Mediation Agreement with you. This is a legal obligation arising under the Bulgarian legislation governing employment mediation activities.

The agreement is registered in the information system of the Bulgarian Employment Agency and retained for the period prescribed by applicable law.

2. Legitimate interest

Where you apply for a position but do not fully meet the requirements of the specific vacancy, we may retain your application for the duration of the recruitment process and for a reasonable period thereafter where necessary to protect our legitimate interests in carrying out recruitment activities. Should we contact you regarding other suitable employment opportunities, your personal data will be processed only where an appropriate legal basis exists.

3. Your consent

Where you have provided your explicit consent, ASTREA RECRUITMENT Ltd. may retain your application after the completion of a particular recruitment process in order to inform you about future employment opportunities that may be of interest to you. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to such withdrawal.

Applicable Legislation

This Privacy Policy has been prepared in accordance with:

• Regulation (EU) 2016/679 (GDPR);
• The Bulgarian Personal Data Protection Act;
• The Bulgarian Electronic Communications Act (where applicable);
• The applicable legislation governing employment mediation activities.

Scope of the Policy

This Policy applies to:

• Job applicants applying through ASTREA RECRUITMENT Ltd.;
• Candidates presented to the Company's clients;
• Candidates referred by the Company's recruitment partners;
• Visitors to the websites https://astrea.bg and https://astrea-bg.com, as well as applicants applying through third-party recruitment platforms such as Jobs.bg, Zaplata.bg, Rabota.bg, and other recruitment channels used by the Company.

This Policy describes the categories of personal data we process, the purposes and legal bases for processing, the recipients with whom personal data may be shared, the applicable retention periods, and your rights under the GDPR.

Personal Data We Collect

We may collect personal data through our websites, recruitment partners, public job portals (such as Jobs.bg, Zaplata.bg, and others), social media platforms (including LinkedIn), telephone conversations, email correspondence, interviews, and any other communication related to recruitment processes.

Depending on the specific circumstances, we may process the following categories of personal data:

• Full name;
• Telephone number;
• Email address;
• Date of birth;
• Nationality;
• Information regarding work permits or employment authorisation, where applicable;
• Information contained in your Curriculum Vitae (CV);
• Education, qualifications, and professional experience;
• Language and professional skills;
• References and recommendations you have provided;
• Information obtained during interviews, assessments, and communications throughout the recruitment process;
• Any other information you voluntarily provide to us.

We process your personal data solely for the purposes for which it has been collected and do not disclose it to potential employers or any other recipients unless there is an appropriate legal basis for doing so. We implement appropriate technical and organisational measures to safeguard your personal data and ensure transparent procedures for its processing.

Our recruitment consultants are available to provide information regarding ongoing recruitment processes, career opportunities, and assistance in exercising your rights under the GDPR.

Important notice

We recommend that you do not include special categories of personal data in your Curriculum Vitae (CV), such as information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health status, biometric data, genetic data, or information concerning your sex life or sexual orientation, unless such information is required by law or is directly relevant to a specific position.

We also recommend that you do not include information contained in identity documents, such as your Personal Identification Number (EGN), national identity card or passport number, date of issue, or expiry date, unless such information is requested at a later stage of the recruitment process and there is a valid legal basis for collecting it.

Data Collected Automatically

When you visit the websites of ASTREA RECRUITMENT Ltd., certain technical information is automatically collected through the server log files. This information may include:

• The type and version of your web browser;
• Your operating system;
• The referring website (where applicable);
• The date and time of your visit;
• Your IP address;
• Your Internet Service Provider (ISP);
• Information about the device used;
• Other technical information necessary to ensure the security and proper functioning of the website.

This information is not used to identify individual visitors to our websites. The data is processed for the following purposes:

• Ensuring the proper operation of the website;
• Maintaining and improving the quality and security of our services;
• Preventing, detecting, and investigating unauthorised access attempts or misuse;
• Complying with legal obligations, where applicable.

Server log files are stored separately from any personal data voluntarily provided by users.

Purposes of Personal Data Processing

Personal data is processed solely for legitimate and specific purposes, including:

• Providing recruitment and career consulting services;
• Connecting candidates with prospective employers;
• Managing recruitment and selection processes;
• Communicating with candidates and clients;
• Informing candidates about suitable employment opportunities;
• Improving the quality of our services;
• Complying with legal obligations;
• Protecting the legitimate interests of the Company.

When you apply for a specific position, your personal data may also be used for the following purposes:

• Assessing your professional experience, qualifications, and skills;
• Conducting interviews and assessments;
• Matching your professional profile with suitable vacancies;
• Providing additional career development and professional consulting services.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects concerning you.

Use of Cookies

The use of cookies on our websites is governed by our separate Cookie Policy, available on our website. The Cookie Policy explains:

• what cookies are;
• which types of cookies we use;
• the purposes for which they are used;
• the legal basis for their use;
• how long cookies are stored;
• how you can manage or withdraw your cookie preferences;
• and how we protect any personal data collected through cookies.

As of the latest update of our Cookie Policy, ASTREA RECRUITMENT Ltd. does not use marketing cookies for profiling users or displaying personalised advertisements. Should this change in the future, the Cookie Policy will be updated accordingly.

Data Retention and Updating

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by applicable law.

Where the processing of your personal data is based on your consent, you may withdraw that consent at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

Where necessary, we may contact you to update the personal data you have provided.

Disclosure of Personal Data

ASTREA RECRUITMENT Ltd. does not sell or disclose personal data to third parties except where this is necessary for the purposes of recruitment, required by law, or supported by another valid legal basis. Personal data may be shared with:

• Prospective employers in connection with a specific recruitment process;
• IT service providers and system support providers;
• External consultants, auditors, and other data processors where necessary for the provision of our services;
• Competent public authorities where required by applicable law.

All data processors engaged by ASTREA RECRUITMENT Ltd. are contractually bound by confidentiality obligations and process personal data solely on our behalf and in full compliance with the requirements of the GDPR.

Your Rights

Under the GDPR, you have the right to:

• Access your personal data;
• Request the rectification of inaccurate or incomplete personal data;
• Request the erasure of your personal data where the legal requirements are met;
• Request the restriction of processing;
• Object to processing where it is based on our legitimate interests;
• Receive your personal data in a portable format, where applicable;
• Withdraw your consent at any time where processing is based on consent;
• Lodge a complaint with the Commission for Personal Data Protection (the Bulgarian supervisory authority).

To exercise any of your rights, you may contact our Data Protection Officer (DPO) using the contact details provided in this Privacy Policy. We will carefully review every request and respond within the time limits established by Regulation (EU) 2016/679 (GDPR).

International Transfers of Personal Data

ASTREA RECRUITMENT Ltd. processes and stores personal data primarily within the European Economic Area (EEA).

Where it is necessary to transfer personal data outside the European Economic Area or Switzerland, such transfers will take place only where a valid legal basis exists and in full compliance with the requirements of Regulation (EU) 2016/679 (GDPR), including the implementation of appropriate safeguards to ensure the protection of personal data.

Protection of Personal Data

ASTREA RECRUITMENT Ltd. implements appropriate technical, organisational, and administrative measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised access, disclosure, or any other unlawful form of processing.

Access to personal data is granted only to employees and other authorised individuals whose duties require such access. All persons processing personal data on behalf of the Company are bound by confidentiality obligations and receive appropriate training on personal data protection.

The Company carries out periodic risk assessments relating to the processing of personal data and, where necessary, implements measures to improve its internal rules, procedures, and information security practices. Where the nature, scope, context, or purposes of the processing require it, the Company conducts a Data Protection Impact Assessment (DPIA) in accordance with the requirements of the GDPR.

In the event of a personal data breach, ASTREA RECRUITMENT Ltd. will take all necessary measures to mitigate its consequences and, where required by law, will notify the Commission for Personal Data Protection within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to the rights and freedoms of affected individuals, the Company will also notify those individuals without undue delay, in accordance with the GDPR.

Updates to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in applicable legislation, the Company's activities, or the manner in which personal data is processed.

Where significant changes are made, the updated version will be published on the Company's website, and the "Last updated" date at the beginning of this Policy will be amended accordingly.

Contact Us

If you have any questions regarding this Privacy Policy or wish to exercise your rights as a data subject, you may contact us at:

Who Processes Your Personal Data?

The controller of your personal data is:

Why Are You Receiving This Notice?

This Notice is intended to explain, in a clear and transparent manner, how ASTREA RECRUITMENT Ltd. processes your personal data when you apply for employment through:

• the websites www.astrea.bg and www.astrea-bg.com;
• job advertisements published on Jobs.bg, Zaplata.bg, LinkedIn, and other recruitment platforms;
• email;
• referrals from business partners;
• in-person interviews;
• telephone conversations;
• career fairs and other recruitment channels.

What Personal Data Do We Process?

Depending on how you apply, we may process the following categories of personal data:

• Full name;
• Telephone number;
• Email address;
• Place of residence;
• Curriculum Vitae (CV);
• Education;
• Professional experience;
• Qualifications;
• Language skills;
• Certificates;
• References;
• Information provided during interviews;
• Results of professional assessments or tests (where applicable);
• Your employment preferences, including preferred position, location, salary expectations, and preferred working arrangement.

We kindly ask that you do not include special categories of personal data (such as information relating to your health, religious or philosophical beliefs, political opinions, ethnic origin, or sexual orientation), unless this is required by law or is necessary for a specific recruitment process.

We also recommend that you do not include your Personal Identification Number (EGN), identity card number, passport number, or other identity document details in your CV unless such information is expressly requested at a later stage of the recruitment process and there is a valid legal basis for collecting it.

For What Purposes Do We Process Your Personal Data?

We use your personal data solely for the following purposes:

• Reviewing your application;
• Assessing your professional profile;
• Arranging interviews;
• Communicating with you throughout the recruitment process;
• Presenting your application to our clients (where applicable);
• Providing employment mediation services;
• Complying with our legal obligations as a licensed employment agency;
• Protecting the Company's legitimate interests in the event of legal claims.

We do not use your personal data for automated decision-making or profiling within the meaning of Article 22 of the GDPR.

What Is the Legal Basis for Processing?

Depending on the circumstances, your personal data is processed on one or more of the following legal bases:

• Taking steps at your request prior to entering into a contract (Article 6(1)(b) GDPR);
• Compliance with legal obligations (Article 6(1)(c) GDPR);
• The legitimate interests of ASTREA RECRUITMENT Ltd. (Article 6(1)(f) GDPR);
• Your consent, where required by law (Article 6(1)(a) GDPR).

Who May Receive Your Personal Data?

Your personal data may be disclosed only where necessary to:

• Employers recruiting for the positions to which you have applied;
• Companies within the ASTREA RECRUITMENT group, where necessary for a specific recruitment process;
• IT service and system providers;
• External consultants and auditors who are bound by confidentiality obligations;
• Competent public authorities where disclosure is required by law.

We do not sell your personal data.

How Long Do We Retain Your Personal Data?

Your personal data will be retained:

• For the duration of the relevant recruitment process;
• For the retention periods required by applicable law, where legally required;
• Where you have consented to remain in our candidate database, for up to three (3) years, unless you withdraw your consent earlier.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised.

Your Rights

Under the GDPR, you have the right to:

• Access your personal data;
• Request the rectification of inaccurate or incomplete personal data;
• Request the erasure of your personal data ("the right to be forgotten"), where the legal conditions are met;
• Request the restriction of processing;
• Receive your personal data in a portable format, where applicable;
• Object to processing based on our legitimate interests;
• Withdraw your consent at any time without affecting the lawfulness of processing carried out before its withdrawal;
• Lodge a complaint with the Commission for Personal Data Protection.

How Can You Exercise Your Rights?

You may contact us at any time using the following contact details:

We will review every request and respond within the time limits established by Regulation (EU) 2016/679 (GDPR).

Complaints

If you believe that your personal data has been processed in breach of applicable data protection legislation, you have the right to lodge a complaint with:

Acknowledgement

By submitting your application, you confirm that you have read and understood this Notice on the Processing of Personal Data When Applying for Employment.

The submission of an application does not automatically constitute acceptance into a recruitment process or the conclusion of an employment or other contractual relationship.

General Information

This Cookie Policy ("Policy") explains how ASTREA RECRUITMENT Ltd., UIC 203088121, with its registered office and management address at 83 Odrin Street, Vazrazhdane District, Sofia, Bulgaria ("the Company", "we", "us"), uses cookies and similar technologies when you visit our websites www.astrea.bg and www.astrea-bg.com.

This Policy has been prepared in accordance with Regulation (EU) 2016/679 (GDPR), the Bulgarian Personal Data Protection Act, and the applicable legislation governing the use of cookies.

What Are Cookies?

Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website.

They enable the website to recognise your device during future visits, remember certain settings and preferences, and support the proper functioning of the website.

Cookies do not, by themselves, contain information that directly identifies you as an individual.

Why Do We Use Cookies?

We use cookies for the following purposes:

• To ensure the proper functioning of our website;
• To improve website security;
• To analyse website traffic and usage;
• To enhance the user experience;
• To remember user-selected preferences;
• To comply with our legal obligations, where applicable.

What Types of Cookies Do We Use?

Strictly necessary cookies

These cookies are essential for the proper operation of the website. Without them, certain website functionalities would not be available. They may include:

• Page navigation;
• Protection of contact forms;
• Protection against malicious activities;
• Technical operation of the website;
• Storage of cookie consent preferences.

These cookies cannot be disabled through the cookie consent banner.

Analytical cookies

Subject to your consent, we may use analytical cookies to better understand how visitors use our website. These cookies may collect information such as:

• Number of visitors;
• Most frequently visited pages;
• Time spent on the website;
• Type of device used;
• Browser type;
• Approximate geographic location.

This information is used solely for statistical purposes and to improve the content and functionality of our website.

Functional cookies

Functional cookies enable the website to remember choices and preferences you have made. These may include:

• Language preferences;
• User interface settings;
• Other available user preferences.

Marketing cookies

As of the date of the latest update of this Policy, ASTREA RECRUITMENT Ltd. does not use marketing cookies for user profiling or the display of personalised advertisements. Should such technologies be implemented in the future, this Policy will be updated accordingly.

Legal Basis

Strictly necessary cookies are used on the basis of the Company's legitimate interest in ensuring the proper operation and security of the website.

All other categories of cookies are used only after obtaining your prior consent through the cookie consent banner. You may change or withdraw your consent at any time.

Third-Party Cookies

Our website may use services provided by third parties that may place their own cookies. Such services may include:

• Website analytics services;
• Social media integrations;
• Embedded maps;
• Embedded video content;
• Other external services.

The use of such cookies is governed by the respective privacy and cookie policies of the relevant third-party providers.

Cookie Retention Period

Cookies may be classified as follows:

Session cookies

These cookies are automatically deleted when you close your internet browser.

Persistent cookies

These cookies remain stored on your device for a specified period or until you delete them manually.

Managing Cookies

When you first visit our website, you may choose to:

• Accept all cookies;
• Reject non-essential cookies;
• Customise your cookie preferences.

You may also delete cookies already stored on your device at any time through your browser settings. Please note that restricting certain categories of cookies may affect the functionality of the website.

Personal Data Protection

Where the use of cookies involves the processing of personal data, such processing is carried out in accordance with the Privacy Policy of ASTREA RECRUITMENT Ltd.

Changes to This Policy

ASTREA RECRUITMENT Ltd. reserves the right to update this Policy periodically to reflect changes in applicable legislation, technologies used, or the functionality of the website. The most current version will always be published on our website.

Contact Information

If you have any questions regarding this Policy or would like additional information about our use of cookies, please contact us: