Update date: 18 August 2023
At Refugeelight.bg (the "Site"), one of our top priorities is protecting the privacy of our visitors. This privacy policy document sets out the types of information that is collected and recorded by Refugeelight.bg, and how we use it.
The content is prepared by the Foundation for Access to Rights - FAR, UIC 176553638. To use its free content, Refugeelight.bg does not require registration. You can visit and enjoy Refugeelight.bg without telling us who you are.
However, in some cases you may need to give us your name, email address, phone number or other personal details in order :
- FAR to provide Intermediary Services ("Services") to recruit workers in Bulgaria; or
- to get in touch with us via our contact forms, LiveChat, or via the Request assistance form
The personal data provided by you will be processed by the Foundation for Access to Rights - FAR, UIC 176553638 in accordance with the data protection legislation, including Regulation (EU) No 2016/679 of the European Parliament and of the Council of 26 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation "GDPR"). The data controller is FAR.
We collect your personal data only to be able to provide the Services available on the Site. Where necessary, certain data may be shared with FAR's donors providing funding for the Services on the Site, This data is shared in accordance with the terms of this Policy.
Contacting us via our contact forms, LiveChat, or via the Request assistance form on Refugeelight.bg will be taken as a sign that you agree to this policy.
Which data is personal data?
"Personal data" is any information related to you and by which you can be identified.
Persons for whom we process personal data
FAR processes the personal data of:
(a) Employers and Employers' Representatives - natural persons;
(b) Individuals designated by the Employer as contact persons;
(c) Refugeelight.bg users using LiveChat, contact forms or the Request assistance form
(d) Individuals designated by the Service providers on Refugeelight.bg's Service map as contact persons;
What data do we collect and process?
Information that you give to us
You decide whether and how to use the Refugeelight.bg Services, including our Intermediary Services. You should note that there are some data you are required to provide, without which we cannot provide you with the relevant Service or part thereof.
Such data include but are not limited to:
(a) Data you provide when using LiveChat or the Request assistance form - names, gender, email addresses, contact phone, date of birth, country of origin, etc.
(b) Data that you provide to enable FAR to provide you with the Intermediary Services, such as information about Employers, Employers' Representatives, Employers' Individuals, contact persons; data protection officer under the GDPR (if any) - name, registered office address, other contact details (correspondence address; business telephone; business email address); UIC/BULSTAT; VAT number, etc.
If you use our Intermediary services for the recruitment of workers in R. Bulgaria and provide contact persons, representatives, etc., you represent and warrant that you have the necessary authorization and that you have previously familiarized the relevant persons with this Policy.
(c) Data provided when signing contracts, declarations, annexes, powers of attorney, invoices, etc. related to the provision of legal assistance or Intermediary Services. These documents may contain name, LNCH/EGN, job title, contact information, handwritten/electronic signature, etc.
(d) Data provided to resolve complaints, signals, inquiries, requests or other forwarded to FAR, received through the electronic forms on the Site, through calls to telephone numbers provided by FAR, and through regular post or email submissions, We store and process this information and the result of this processing.
(e) Special Categories of (Sensitive) Data. The FAR Services and the functionalities provided on the Site are not intended to collect, store and process special categories of data within the meaning of Article 9 and Article 10 of GDPR. You are obliged not to store such data. In addition, Employers and their representatives should not require job applicants to send sensitive data. FAR is under no obligation to and does not monitor the availability of the data referred to herein on the Site.
(f) Data related to Sevice providers that are listed in the Service Map of Refugeelight.bg
(g) FAR may process other data relating to you where you provide it.
Data related to the process of using the Services
(a) Pre-aggregated user data collected by third parties (including Meta, Google) for analytics purposes. Website user data is collected through the use of cookies on our website or through information associated with your profile when you are logged into your Google account. This information is only available in an anonymised format, which means it is not data we can link to your identity.
Such data may include demographic and user activity data (e.g., age, gender, city, country, language, time of engagement, and session source).
(b) Contractual and financial information relating to the execution and performance of the Services Agreement between you and FAR, such as:
- Information on contracts;
- Information related to payments made and due for the Services (information may include name, bank, bank account number, etc.) when a paid service is provided;
- Information related to the administration and provision of the Services;
- History and information about requested Services;
- History and usage information about the Services;
- Other information created or provided in the process of using the Services.
(c) Some of the Services have settings and notifications (including by email) that make it easier for you to use the Site. FAR processes relevant information for this purpose.
Purposes of processing personal data
FAR collects, uses and processes the information described above for the purposes set out in this Policy, the Terms of use and the Terms and Conditions for Employers, which may be:
- To communicate with you: we use your contact information to respond to your inquiries and direct you to the resources and services you need if you ask us to.
- To decide what information to provide: we collect data to help us understand what information refugee and migrant communities need and what issues they face. With this information, we can make sure that the information we provide is useful and that our outreach is driven by the issues and needs of the community we support.
- To provide information and analytics: we collect data about your experience and interaction with our website to improve our site.
- For the performance of services and for the conclusion and performance of contracts for the provision of the Services between you and FAR, including intermediary services;
Such services are, for example but not exhaustively, LiveChat, the Request Help form. In addition, these purposes include communicating with you, including by email, as necessary to provide the Services and/or notifying you of changes to the Services. - To protect and enforce the legitimate interests of other users of the Services, third parties and FAR, which include:
- Ensuring the proper functioning and use of the Site, maintaining and administering the Services, resolving disputes, identifying and preventing malicious activity;
- Detecting and resolving technical or functionality issues;
Some or all of the above data may be processed for these purposes.
6. Receiving and processing signals, complaints, requests and other correspondence;
7. Exercise and protect the rights and legitimate interests of FAR, including through legal proceedings, and assist in exercising and protecting the rights and legitimate interests of other users of the site and/or third parties affected.
8.For purposes for which you have given your explicit consent;
9. For purposes necessary for the performance of FAR's legal obligations. These are purposes such as:
- Financial and accounting activities where it is necessary to process and store information required by law in order to meet tax, accounting and other reporting obligations;
- Activities to comply with statutory obligations to preserve or provide information upon receipt of an appropriate order from competent governmental or judicial authorities, in compliance with FAR's legal obligations to notify you of various circumstances relating to your rights, the Services provided or the protection of your data, etc.;
- Activities to comply with reporting obligations, obligations under Regulation (EU) 2016/679 and applicable law and other applicable obligations.
10. For purposes necessary for the implementation of FAR's obligations to donors funding the services provided at Refugeelight.bg such as:
- Routine activities such as transferring personal data to beneficiaries of free services, including providing information or legal assistance to support a specific case or carrying out specific protection activities;
- inspection, monitoring, audit and investigation;
- provision of statistics on demographic criteria - gender, age group, country of origin, etc.
Storage period
When storing data, we apply the general principle of storing minimum data and for no longer than the necessary period to provide the Services, ensure their security and reliability and the requirements of the law.
The data shall be kept in the archives of FAR for a maximum of 5 /five/ years from the termination of the service or up to 10 /ten/ years in the case of the provision of intermediary services to recruit of workers in Bulgaria, starting from the the year following the year in which a payment is due. Thereafter the data will be destroyed. FAR will retain your personal data only for the purposes set out in this Privacy Policy and to the extent necessary to comply with FAR's legal obligations, resolve disputes and enforce our policies.
In the event of a legal dispute or proceeding requiring the retention of data and/or a request from a competent government authority, it is possible to retain data for longer than the specified periods until the final conclusion of the dispute or proceeding before all instances.
These time limits are subject to change if a different retention requirement is established under applicable law.
When providing services to Employers in the Republic of Bulgaria, a change in or termination of the relationship between an Employer or its Representatives does not result in a change of the above time limits, due to the fact that information about the orders placed, instructions and actions of specific Representatives is necessary for evidence and accountability in relation to contractual and legal obligations.
Provision of information
FAR does not provide your personal data to third parties in any other way than described in this Policy and as provided by law.
Employers and Employers Representatives.
Employer Data, such as the details of Representatives, services requested, job offers posted and other actions, is accessible to the Employer and its Representatives.
Suppliers and subcontractors
FAR uses subcontractors and service providers such as server and network equipment, accounting services, etc. When working with subcontractors and suppliers, FAR requires that they strictly comply with our instructions in accordance with this Policy, the Terms of use and the Employer Terms and Conditions.
Third parties
Your personal data may be provided to third parties only in the following cases: where this is provided for by law; if duly requested by a competent governmental or judicial authority; where we have obtained your explicit consent to do so; where this is necessary to protect the rights and legitimate interests of FAR and/or other users of the Services; where this is necessary in order to fulfil FAR's obligations to donors providing funding for the free services on the Site, in accordance with the terms of this Policy.
Your rights under the EU General Data Protection Regulation
You have rights under the GDPR, including:
- Right to information. This Policy aims to inform you in detail about the processing of your personal data in relation to the Services provided.
- The right of access to your personal data - you have the right to obtain confirmation of whether your personal data is being processed, access to it and information about its processing and your rights in relation to it.
- The right to have your personal data rectified if it is inaccurate or incomplete;
- The right to request that your personal data be deleted or removed if there is no reason and/or legal obligation for its further storage and processing;
The right to object to the processing of your personal data and to restrict the processing of your personal data in certain circumstances;In the event of such an objection, we will consider your request and, if justified, we will comply with it. If we consider that there are compelling legitimate grounds for the processing or that it is necessary for the establishment, exercise or defence of legal claims, we will inform you of this.
- Right to restriction in relation to data processing. The Regulation provides you with the possibility to restrict the processing of your personal data if the grounds for doing so set out in the Regulation exist.
- The right to request the transfer of your personal data to another party;
- Right to data portability. You have the right to receive the personal data you have provided relating to you and to use that data.
- The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless there are grounds for doing so under applicable data protection law and appropriate safeguards are provided to protect your rights, freedoms and legitimate interests.
- Where you have consented to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent. Please note that withdrawing your consent will not affect the lawfulness of the processing of your personal data on the basis of your consent prior to withdrawal.
These rights may be limited, for example, if complying with your request would disclose personal data about another person or if you ask us to delete information that we are required to keep by law or have a compelling legitimate interest in keeping.
Accuracy of information
FAR is not responsible for the accuracy of the data you provide, does not carry out checks to this effect and does not guarantee the true identity of the individuals who have provided the data. In all cases of suspicion on your part of fraud and/or abuse, please notify us immediately. You agree that when providing any information on the Site, you will not violate the rights of others in relation to the protection of their personal data or their other rights.
Log files
Refugeelight.bg follows a standard procedure for using log files. These files log visitors when they visit websites. All hosting companies do this as part of the analysis of hosting services.
The information collected from the log files includes IP address, browser type, Internet Service Provider (ISP), date and time, referring/exit pages and possibly number of clicks. They are not linked to any personally identifiable information about you.
The purpose for collecting this information is to analyze trends, administer the site, track user movement around the site, and collect demographic information.
Cookies
"A cookie is a small amount of data that a website stores on a visitor's computer or mobile device.
We use cookies on our website in connection with its operation and to collect statistics for analysis. The cookies used are used to distinguish users and sessions, to define new sessions, to submit requests, to store the source of traffic and how the site is accessed.
You can always disable both our cookies and third-party cookies by setting your browser correctly. In this case, you may lose some of the functionality of some of the services.
If you use a link that takes you to another site, it will have its own cookies and security policy, over which we have no control.
Hyperlinks to other websites
This Privacy Policy does not cover hyperlinks to third-party websites listed on Refugeelight.bg. We encourage you to read the privacy policies of other websites you visit.
Changes to the privacy policy
We reserve the right to change this policy and any other relevant policies or procedures at any time without notice to you. Any changes we may make to this Policy in the future will be posted on Refugeelight.bg and we encourage you to check and review the Policy regularly to ensure that you understand how we may process your personal data. Any changes we may make to this Policy will take effect from the date on which those changes are posted on this page. Where appropriate, we may also notify you of any changes made by email.
IF YOU WANT YES
access and review the information we hold about you
AND/OR
you believe the information we hold about you is incorrect, incomplete or needs to be redacted or deleted, please email [email protected]. You can contact this email for any other questions about our privacy policy.
Address for correspondence. Address for correspondence. "Prof. 5 - ground floor
Where you are dissatisfied with any aspect of the processing of your personal data, you have the right to complain to:
Bulgarian Commission for the Protection of Personal Data. "Prof. 2, Sofia 1592
E-mail: [email protected]
Website: www.cpdp.bg