Privacy policy

PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA BY “REFEREL CONSULTING” LTD

Date: 10.10.2025

1. Data Controller and Contact Details

The website www.referelconsulting.eu is owned and controlled by Referel Consulting Ltd., UIC 207116012, with registered office and management address: Sofia 1415, Vitosha District, Simeonovsko Shose Blvd., No. 97K, Entrance B, Floor 2, Apartment 7; correspondence address: Sofia, 10 Poduevo St., Office 12, email: [email protected], phone: +359 885 313 737.

We understand that it is important for you to know how we collect, store, and share personal data processed in the course of our activities. Through this Privacy Policy, we provide you with the information required by applicable legislation.

2. Who Is This Privacy Policy Intended For?

This Privacy Policy applies to all individuals whose personal data we process in the course of our commercial activities, including but not limited to:

  • visitors to our website and social media profiles;

  • job applicants;

  • individuals who submit inquiries by phone, email, or via social media;

  • business partners and their employees.

3. What Personal Data Do We Process, for What Purposes, on What Legal Grounds, and for How Long?

The type of personal data we process depends on the purpose for which it is required and the activities through which the data is obtained. We do not use your data for automated decision-making, including profiling, based solely on automated processing.

3.1. Visiting the Website: https://referelconsulting.eu/

When you visit https://referelconsulting.eu/, we record the following data in log files: IP address; user operating system; time of visit; pages visited, and other technical information. We process this information to ensure the proper functioning of the website, such as establishing connections, identifying errors, and analyzing system security. The legal basis for this processing is our legitimate interests, namely ensuring the website’s functionality and security. Data is stored for the shortest period necessary for technical operation.

During your visit, we also generate data stored on your end device until the end of the session. This storage is strictly necessary for the website to function and does not require your consent.

3.2. Applying for Job Positions

When you apply for a position with the Company, we process:

  • data contained in your CV – names, email, correspondence address, phone number, nationality, date of birth, gender, residence; education and qualifications; professional experience and positions held; skills; language proficiency; possession of a driving license; and any additional information you choose to provide;

  • photograph – providing a photo is optional; if submitted, it will not be processed using facial recognition technologies;

  • data contained in application messages or cover letters;

  • data created during the recruitment process, such as assessments of professional and communication skills.

Providing personal data is voluntary, but without at least prior experience and contact information, your application will not be reviewed.

We process your personal data for recruitment purposes, including:

  • evaluating applications and making hiring decisions;

  • verifying the accuracy of submitted information;

  • communicating with you during the recruitment process.

We may also process data for the establishment, exercise, or defense of potential legal claims.

Processing is based on your consent, given through your active application. You may withdraw your consent at any time by emailing [email protected]. Withdrawal of consent equals withdrawal of your application.

3.3. Processing of Inquiries

To facilitate interaction with clients and prospective clients, we process data submitted through phone, email, or social media inquiries. This may include names, email addresses, phone numbers, and other information provided during communication. Please do not provide information unrelated to our activities.

These data are processed under joint controllership with MV Industries Ltd., UIC 206506145, registered office: Sofia, Slatina District, 28 Kaymakchalan St. You may exercise your rights with either company.

The legal basis is our legitimate interest in effectively managing relationships with clients and prospects. Data is stored for up to 1 year, after which it is deleted.

3.4. Social Media Profiles

We maintain profiles on Facebook (Facebook Ireland Ltd., Dublin) and LinkedIn (LinkedIn Ireland Unlimited Company, Dublin). When you visit these profiles, the respective platform collects data through cookies and similar technologies. Please refer to each platform’s privacy policy for more information. Processing is based on consent implied by your interaction with our pages.

3.5. Interaction with Contractual Partners

For managing contractual relationships, we process:

  • for individual clients or suppliers: names, personal identification number, address, phone, email;

  • for representatives of individuals or legal entities: names, address, phone, email, position;

  • for employees involved in communication: names, position, email, phone.

Legal grounds include necessity for contract performance, compliance with legal obligations, and legitimate interests related to efficient business management and service updates. Data is retained for up to 10 years in accordance with applicable legislation.

4. Sources of Personal Data

Data is usually obtained directly from you. In some cases, it may be obtained from third parties or public registers.

5. Data Recipients

We may grant access to data to service providers supporting our operations, such as hosting and cloud services (e.g., SuperHosting.BG, Microsoft Office 365). These processors are contractually obligated to ensure high data security.

We do not transfer data to third countries without appropriate safeguards. Microsoft Office 365 participates in the EU–U.S. Data Privacy Framework, ensuring adequate protection.

We also provide data to competent authorities when required by law.

6. Data Security

We implement reasonable physical, technical, and organizational security measures to protect personal data against loss, misuse, alteration, destruction, or damage, in line with legal requirements. Measures are regularly reviewed and updated.

7. Your Rights

You have the right to request:

  • access to your personal data;

  • correction of inaccurate or incomplete data;

  • erasure of data in specific cases;

  • restriction of processing;

  • withdrawal of consent at any time;

  • data portability where applicable;

  • objection to processing based on legitimate interests.

To exercise your rights, contact us at [email protected]. Requests must include your identification details and preferred correspondence method. Additional identification may be required if necessary.

If you believe your data has been processed unlawfully, you may file a complaint with the Commission for Personal Data Protection, Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., https://www.cpdp.bg/, or with the competent court.