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PRIVACY POLICY / PERSONAL DATA PROCESSING NOTICE

Controller
The data controller is Employment and Recruitment Agency HR Bulevar d.o.o. Belgrade, Šumatovačka 72, Belgrade, Company Registration No. 21005517, Tax ID 108466754. Privacy contact: jobsserbia@hrbulevar.rs. 
 
2. Personal data we process
• identification and contact data: first name, last name, date of birth where required, nationality, address, e-mail, telephone/WhatsApp;
• data from passports and other identification documents where required for an immigration/employment procedure;
• CV, education, diploma, qualifications, work experience and professional certificates;
• data required for Visa D/Single Permit and related documentation, including data required by competent authorities;
• order, payment, invoice, complaint and communication data;
• technical data concerning website use (e.g. IP address, device, logs) to the extent required for security, contracting and, subject to an appropriate legal basis, analytics;
• data relating to employers/partners and their contact persons.
Special categories of personal data (e.g. health or biometric data within the meaning of applicable law) are processed only where there is an appropriate legal basis and where genuinely necessary for the specific purpose. 
 
3. Purposes and legal bases

Purpose
Typical legal basis
Analytics/marketing cookies
Consent where cookies/technologies are non-essential and require consent
E-mail/WhatsApp marketing and newsletter
Consent where required; separate and withdrawable
System security and prevention of abuse
Legitimate interest, subject to a proportionality assessment
Complaints and legal claims
Legal obligation and legitimate interest in establishing/defending rights
Accounting, fiscalization and tax records
Legal obligation
Employment and mediation
Application of relevant legislation, pre-contractual/contractual steps, legitimate interest or another appropriate basis depending on the specific process
Performance of Visa D/Single Permit (Temporary Residence & Work permit) administrative service
Performance of a contract and pre-contractual steps; legal obligations where applicable
Responding to enquiries and pre-contractual steps
Steps taken at the person’s request before entering into a contract / legitimate interest where appropriate

4. Recipients
Personal data may be disclosed to competent government authorities, diplomatic-consular missions and competent authority portals where necessary for the requested procedure; to relevant employers/user companies to the extent required for a lawful employment purpose; to IT/hosting providers (including Wix infrastructure), payment processors (e.g. PayPal where selected), translators and other processors only to the necessary extent and subject to appropriate contractual/legal safeguards.
 
5. Transfers to other countries
Due to the international nature of the Platform and the technology/payment services used, certain recipients may be located outside the Republic of Serbia. Before any such transfer, HR Bulevar shall establish an appropriate transfer basis and safeguards in accordance with the Personal Data Protection Act. Information about the specific transfer mechanism may be requested through the privacy contact address.
 
6. Retention periods
Personal data are retained only for as long as necessary for the purpose for which they were collected and for the periods required by tax, accounting, employment, immigration and other applicable laws. For candidate profiles and documentation for which no specific longer statutory period applies, HR Bulevar must internally define and publish a specific period or criterion 24 MONTHS FROM LAST ACTIVITY. Marketing data are retained until consent is withdrawn, while minimal evidence of consent/withdrawal may be retained for compliance purposes.
 
7. Data-subject rights
In accordance with law, depending on the circumstances and legal basis, a person may request access, rectification, erasure, restriction of processing and data portability, object to processing, and withdraw consent without affecting the lawfulness of processing carried out before withdrawal. The person has the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.
 
8. Whether data are mandatory
Fields necessary for performance of the contract or procedure must be marked as mandatory, together with an explanation of the consequences of failing to provide the data. Data that are not necessary must not be indirectly made conditional on marketing consent or another unrelated purpose.
 
9. Security
HR Bulevar applies appropriate technical and organizational measures proportionate to risk, including access control, limitation of permissions, account protection, access logging where appropriate, secure document transmission, and procedures for incidents/personal-data breaches.

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