This Privacy Policy outlines the fundamental principles governing the protection of your privacy by Liberty Technology (“we,” “our,” or “us”).

This Policy articulates Liberty Technology’s commitment to safeguarding the privacy of data submitted through our Website. It is designed to clarify the data we collect, the reasons behind its collection, and how we utilize it. Please read this Policy and our Cookies Policy and Terms of Use before providing personal data.

By choosing to use our Website, you acknowledge and affirm your understanding and agreement with the content of this Policy.

This Policy is applicable when we act as the data controller, determining the purpose and means of processing the personal data you submit. We have also specified areas where the processing of your personal data is entrusted to third parties, ensuring transparency.

Upon your initial visit to our Website, we will seek your consent to use cookies per our Cookies Policy.

What data do we collect?

In the web site’s operation, we collect your Data – information identifying you as an individual, including your name, email address, home or business address, and telephone number (“Personal Data”).

We gather Personal Information provided by you, including details when you express interest, communicate with us, apply for a job vacancy, request information, submit an inquiry, or register to receive our newsletter through our Email Marketing Program.

The general categories of Personal Data we may collect and process include, but are not limited to:

  • Usage Data: Information about your visits to and use of the website, such as IP address, geographical location, visit duration, date and time, page views, and navigation paths.
  • Correspondence Data: Information provided for responding to your inquiries, comments, or complaints, including your full name, email address, and phone number.
  • Vacancy Data: Information submitted for job applications, encompassing details about your education, work experience, cover letter, CV, and any additional documents.
  • Notification Data: Information provided for subscribing to our email notifications, newsletters, and any other Personal Data you send.

You are advised not to supply anyone else’s Personal Data to us.

Processing of personal data

When you submit Personal Data through our Website, we utilize and process it for the specific purposes outlined below:

Usage data:

  • Purpose of processing: Ensure the security of our Website, diagnose and prevent service or technology issues affecting the site, prevent fraud, better comprehend the characteristics of visitors to enhance the Website and Services, and ensure users comply with the Terms of Use.
  • Legal basis for processing: Our legitimate interests.

Correspondence data:

  • Purpose of processing: Facilitate responses to inquiries, and complaints about our Services, Website, or job vacancies.
  • Legal basis for processing: Our legitimate interests.

Vacancy data:

– Purpose of processing:

  • Enable participation in our selection process and assess your application for a specific role.
  • Communicate with you throughout the recruitment process.
  • Analyze your application for other current or future roles.
  • Your vacancy data may be further processed, anonymized, and stored post-selection for statistical purposes.
  • Utilize analytical activities, employing automated processing to identify suitable candidates based on criteria outlined by us or typical for the applied role. The final hiring decision remains with our recruitment team.
  • Legal basis for processing: Our legitimate interests.

Notification data:

  • Purpose of processing: Send relevant notifications, email newsletters, communications, and updates about our business and job opportunities. Delivery can be via post or, if explicitly agreed upon by you, through email or similar technology you have specifically requested. You can opt out at any time.
  • Legal basis for processing: Your consent.

Beyond these specific purposes, we may process your Personal Data within the bounds of applicable law, believing in good faith that such actions are necessary for:

  • Compliance with legal obligations or governmental requests.
  • Defense of our rights in legal or administrative proceedings.
  • Protection against legal liability.

Periodically, we may engage third parties to perform specific functions related to processing your Personal Data. Examples include maintaining a database of CVs for job applicants via our Website and managing email notifications and newsletters for users.

Disclosure of personal data

We may reveal and/or transfer your Personal Data to the following entities:

  • Our employees, officers, suppliers, subcontractors.
  • Third-party processors are designated as our data processors.
  • Affiliate companies and subsidiaries include employees, officers, suppliers, and subcontractors.

This disclosure will occur to the extent reasonably necessary for the purposes outlined in this Policy.

We will disclose your Personal Data:

  • To the extent required by law or public/government authorities.
  • In connection with ongoing or potential legal proceedings and compliance with legal processes.
  • To the extent reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishing, exercising, or defending our legal rights. This includes court proceedings and administrative or out-of-court procedures, where information may be shared for fraud prevention and reducing credit risk.
  • To enforce our Terms of Use.
  • To empower us to seek possible solutions or mitigate potential harm.

Except as this Policy stipulates, we will not furnish your Data to third parties.

International data transfers

As a global consortium of companies, our presence extends across various regions, with a significant footprint in China, Vietnam, and Cambodia.

The information we collect may be stored, processed, and transferred among any countries where we operate. This facilitates the utilization and processing of information by the guidelines outlined in this Policy.

For legitimate business activities and in compliance with applicable law, Personal Data may be transferred outside the country of origin for collection and/or processing. 

Moreover, the Company might engage Third Parties to store and/or process Personal Data in facilities outside the country where the data was initially collected and/or processed. 

Data retention and deletion

We commit to retaining and processing your Personal Data only for the necessary duration stipulated for the specified processing purpose. The applicable timelines for retaining your Personal Data vary depending on the processing purpose, and we determine these based on factors such as:

The duration required to provide our Services to you.

  • A reasonable timeframe to respond to your information requests, and complaints, or evaluate and assess your job application.
  • The sensitivity of your Personal Data.
  • Your consent to an extended retention period.
  • Legal, contractual, or similar obligations mandating a minimum retention period.

Notwithstanding other provisions in this section, we retain documents, including electronic files containing Personal Data:

  • To comply with applicable laws.
  • When we believe these documents might be relevant to ongoing, imminent, or prospective legal proceedings.
  • For establishing, exercising, or defending our legal rights, including providing information for fraud prevention and reducing credit risk.
  • Upon the expiration of the retention period, we will securely delete your Personal Data to prevent reconstruction or unauthorized access. Specifically, Vacancy Data will not be retained for more than 2 years if we determine that the submitted CV is not pertinent to available vacancies at the time of submission. In cases where you request to be excluded from our services (self-exclusion), we will retain this information for a maximum of 7 years, as mandated by legal and regulatory requirements, from the date of the request before initiating deletion.

Personal data security

Ensuring the security of your Personal Data is of utmost importance to us. We implement reasonable technical and organizational precautions to prevent any loss, unauthorized access, disclosure, destruction, misuse, or alteration of your Personal Data. 

Our comprehensive security measures include suitable physical, electronic, and managerial procedures designed to safeguard and secure the Personal Information we collect.

All Personal Information you provide is stored in a secure computing environment, carefully protected to prevent unauthorized access. 

Access controls are meticulously managed so that only individuals with a legitimate need can access Personal Information. Our staff undergoes thorough security training and is obligated to adhere to a comprehensive set of security policies, procedures, and standards integral to their respective roles.

Revisions and updates

This Policy may be revised or updated at any time without prior notice. The revised Policy becomes effective upon being posted or published on our Website. If you disagree with or do not wish to accept the revised Policy, you must discontinue using our Website. Regularly check this page to ensure you are content with any modifications to this Policy.

Your data rights

You possess various rights concerning the Personal Data you’ve shared with us, aligned with applicable legislation. Summarized below:

(a) Right to Access:

Request access to your Personal Data, including information about the processing purpose and recipients. Please verify your identity while supplying a copy of your held Personal Data.

(b) Right to Rectification:

Rectify any inaccurate Personal Data and complete any incomplete Personal Data about you, considering the processing purposes.

(c) Right to Erasure:

Under certain circumstances, request the erasure of your Personal Data without undue delay. Conditions include no necessity for the original processing purpose, withdrawal of consent, objection to processing under specific data protection rules, processing for direct marketing purposes, or unlawful processing.

(d) Right to Restrict Processing:

In specific situations, limit the processing of your Personal Data. While processing is restricted, we may store but not process your Personal Data.

(e) Right to Object to Processing:

Object to processing your Personal Data under specific legal bases, such as legitimate interest. We will cease processing unless compelling legitimate grounds override your interests or for legal claims.

(f) Right to Data Portability:

If automated means and the legal basis are consent or performance of a contract, receive your data in a structured, commonly used, and machine-readable format, unless it adversely affects others’ rights and freedoms.

(g) Right to Lodge a Complaint to a Supervisory Authority:

If you believe our processing of your Personal Data violates data protection legislation, you can complain to the Bulgarian, Cyprus, or other Supervisory Authorities.

(h) Right to Withdraw Consent:

Withdraw consent for processing based on consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

Third-Party Websites

Our Website may contain hyperlinks and details of third-party websites. We are not responsible for the privacy policies and practices of third parties.

Sensitive Information

Do not send or share sensitive Personal Data (e.g., racial or ethnic origin, political opinions, religion, beliefs, health, genetic or biometric data, trade union membership).

Contact Us

You can reach us through:

  • Post, using the addresses published on the Website
  • Using our Request Information section on our Website
  • By telephone, on the contact number published on our Website
  • By email, using the email address published on our Website.

 

Effective as of 15/01/2024