Last updated: 28.04.2021
1. Introduction
MM Solutions EAD (MMS) is a Bulgarian company, part of Thundersoft Group, and a world leader in the fields of image quality tuning and testing, both for the mobile device consumer market and the automotive industry. We are highly involved and strongly engaged in information security and personal data protection.
The present privacy policy describes the reasons for data processing, how we collect, use, and protect all the entrusted personal data, and what your rights are in this regard. In connection with collecting and processing personal data, our policy is to do that in a conscientious and transparent manner.
The present privacy policy refers to the processing of personal data provided by job applicants directly to the company’s email, carees@mm-sol.com, or indirectly through recruitment agencies and online platforms.
2. Confidentiality and data safety principles
To protect your personal data, MMS has adopted a series of technical and organizational measures approved by the company management and incorporated into everyday data processing. Technical measures include appropriate actions regarding data safety and the risks of data loss minimization, data change, and unauthorized access to data. These measures are implemented through data encryption, data transfer restrictions, and the introduction of technological solutions that allow data subjects to exercise their rights. The organizational measures include providing personal data access only to authorized personnel responsible for data processing, training these personnel, and controlling physical access to electronic and paper records.
MMS adheres to the following principles related to confidentiality and data protection:
Lawfulness, fairness and transparency
MMS is processing your personal data in compliance with the applicable law in a fair and transparent way. Collecting your personal data is lawful and on the basis of the legitimate interests of the company in its capacity as a data administrator. To achieve fair data processing, we use your personal data only for the purposes defined at the moment of data collection. Our actions are transparent, and we use clear, simple, and understandable language when providing information about personal data collection, processing, and protection to the relevant data subjects.
Principle of data minimization
The personal data MMS collects in its capacity as a data administrator is limited explicitly to the data that is strictly necessary for the particular processing purpose. Internal checks are regularly performed by the Data Protection Officer (DPO) to guarantee that the collected data is still up-to-date, relevant, and not excessive.
Accurate and up to date data
MMS keeps all collected personal data accurate and up-to-date at any moment and guarantees that there are appropriate measures adopted to keep data correct and precise, taking into account data volume, how quickly the changes could be implemented, and other relevant factors.
Accountability
MMS follows the personal data accountability principle in order to properly document all the processing activities such as keeping a register of these activities, having regular impact assessment (preliminary risk assessment), executing voluntary certifying mechanisms and/or following an internal code of conduct.
3. Personal data to be collected and processed
Concerning job applicants, MMS does not collect specific (sensitive) personal data. The information we collect is standard personal data:
First name and surname
Curriculum vitae (CV)
Contact information (telephone number, e-mail address)
Education, degree and qualification
University name
Work experience
Upon the job interview, MMS keeps the technical test results and some relevant data regarding the candidate’s personal qualities shown during the interview.
4. Collecting and processing of personal data
In connection with the recruitment process, you, in your capacity as job applicants and data subjects, provide your own personal data directly to us via email or indirectly through recruitment agencies or online platforms. Your consent for your personal data processing will be asked for and received by the relevant data administrator in accordance with the applicable legislation. Prior to collecting any data from you, we will give you all the necessary information you need to know about the way we’re going to treat your personal data.
Your personal data will not be used for automatic decision-making, including profiling.
5. Legal basis for data processing
MMS collects the abovementioned personal data on the basis of necessity with regard to the company’s legitimate interest in its capacity as a data administrator and for the purposes of new employees’ recruitment with respect to the company’s interests as a commercial entity.
6. Storing of personal data
MMS stores your personal data in accordance with the “Data Storage and Destruction Procedure” and “Data Storage and Destruction Schedule” and only for the period of time necessary to fulfill the purposes for data collection and processing, which is exactly 6 months upon the final decision for the relevant job applicant. Technical test results and data regarding the candidate’s personal qualities for the rejected applicants are kept for a period of one month from the final decision in case there’s an option to re-evaluate the interview results and change the decision in the candidate’s favor.
Upon the storage term expiration, the relevant hard copies of the data are destroyed on a shredder, and electronic data is deleted. A protocol is issued documenting the type and volume of the data being destroyed.
7. Access to personal data
Only the Human Resources (HR) team responsible for job applicants’ data processing has access to your personal data. The data concerning your education, degree, and work experience will be disclosed to certain managers and heads of departments in MMS for initial document assessment and decision-taking to invite the successful candidates to an interview.
The collected personal data in connection with the recruitment process will not be disclosed or provided to third parties.
8. Data subjects’ rights
At any moment during the process of data storage and processing, you, in your capacity as a data subject, have the following rights:
Right of being informed regarding what data of yours is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties.
Right of access to your personal data - right to request a copy of the information that MMS in its capacity as a data administrator holds on you.
Right of rectification – right to correct or update data that is inaccurate or incomplete.
Right to restrict processing – right to request that we limit the way we process your personal data.
Right to be forgotten - in certain circumstances you can ask that any personal data, we hold on you, be erased.
MMS provides conditions that guarantee your opportunity to exercise these rights by contacting the company DPO or getting in touch with our HR team, who will reply without delay and fulfill your request within the lawful timeframe.
9. Contact information
If you have any questions regarding the present privacy policy or how and why your personal data is being processed, please contact:
Name: Mariela Trizlova Position: DPO Telephone number: +359 2 416 91 86 / Mobile number: +359 898 63 93 40 E-mail: mtrizlova@mm-sol.com
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