Uploaded on: 12/01/2022

Last revised: 12/01/2022


This agreement applies to the processing of personal data between Plegi Ltd., with EIC: 205945851, with registered office and management address: Sofia, Bulgaria, 1303, Vazrazhdane district, "Sredna Gora" street No. 48, fl. 4, apartment 8, with contact email: info@pleggi.com (hereinafter "Pleggi") and The Employer (You) (in the sense of the general conditions for HR for the Platform, hereinafter referred to as "Employer") on the platform www.pleggi.com (called hereinafter the "Platform" or "Site"). This Agreement applies to the cases in which the Employer processes personal data of the Users through the Platform, provided that they, in turn, have allowed this explicitly and with their own freely given consent, and the cases in which the Employer provides personal data to its Representatives are also affected here, as such the agreement is only in addition to all privacy policies that are applicable to the Site and detailing the interactions between The Employer, Pleggi and the Users of the Site. In the context of processing in the Platform, the Employer is the processor personal data, and Pleggi - personal data controller. The employer as processor is responsible for the rights of data subjects to comply, with the level of protection and compliance to be, if not identical to the level that Pleggi supports, at least minimally the same. Pleggi requires from The Employer processing the data of its Representatives (for the purpose of functioning of the Platform for the purposes for which it was created, namely a recruitment tool that based on online based computer games to assess the skills of Users and in connecting them with The employer, they establish their compatibility for future employment relationships), this data includes only first name, last name, work phone and email address, photo, position/s, in what capacity they are your representatives/persons for contact, for the sole purpose of providing the services found in the Platform of the Employer, proving that the person has the right of access and connection to necessity. Personal data of Users (according to the general conditions for users, referred to as “Users”) will be shared, through the Platform with The Employer, only after separate consent to this from the relevant User (which consent will be expressed in the voluntary provision of data from The User of the Employer through the Platform or outside it, as the User can contact the Employer, through the Platform within it, through its functionalities or by forwarding to the Employer a link in which find his personal data stored on the Platform in his personal profile), processed information about Users may include - name, last name, phone number, email address, photo, gender, age, city where living/looking for work, education (completed education/qualification degree, when he completed his education, whether he is a learner, student or looking work), professional interests, how many years of professional experience he has (by employment and/or civil contract), reports on the User's skills (the results of which are based on tests, in the form of online based computer games), how many and what foreign languages he knows, field/s, c which/which is/have been acquired the professional experience desired by him/her remuneration, CV (resume), certificates, licenses, professional values, this data will become available (in whole or in part) to the Employer only after the express permission of the specific User. This an agreement is effective from the moment you agree to it. The Employer and Pleggi agree to comply fully with the requirements of Regulation (EU) 2016/679 and other applicable legislation in this area. The employer agrees to familiarize himself with the policies for the protection of personal data, cookies of Pleggi and to assume analogous or at least at the same level measures to protect personal data that become available to him through (direct or indirectly) the Platform. The Employer may share with the Users its own privacy policies as it sees fit and if it wishes to apply them to the Users, they will be valid on the Platform only if they cover at least the minimum in it by Pleggi.

1. Processing of personal data For information in this Agreement for the processing of personal data is accepted (“Processing”) that it is any operation or set of operations, carried out with personal data or a set of personal data through automatic or other means means such as collecting, recording, organizing, structuring, storage, adapt or modify, retrieve, consult, use, disclose through transmitted, as is the legal definition.

2. Representatives of the Employer

2.1. In order to provide the services on the Platform and ensure the access to them Pleggi, processes data about the persons representing The employer when using the services ("Representatives").

2.2. Pleggi processes the personal data of the persons - Representatives of The employer, as this is done in accordance with the Policy privacy policy for the HR platform available here.

2.3. When adding additional users in the account of the Employer, You declare that you have the necessary authorization and that you have informed and familiarized the individuals with the Privacy Policy data and this Pleggi Agreement before doing so.

3. User's Sharing of Employer Information

3.1. After registration/agreement with Pleggi, Pleggi will generate link that the Employer (You) will be able to distribute on which they will be able to to play online based computer games that assess skill and to fill in the above-mentioned data for the User, the data of the Users, have played the games, through this shared link they will also be available to the Employer and for Pleggi. All this will happen only and only according to the will of everyone parties in this respect the Employer, Pleggi and the Users and if even one of them disagrees, it won't happen.

3.2. The site is a technological platform providing access to a skills assessment tool based on which Employers can carry out a better selection of personnel for future jobs legal relationship, such as the processing of any information by Pleggi itself subject only and solely to the fulfillment of this specific purpose and to the legal basis - express consent of each of the parties in the created are in connection with this legal relationship. At the request of either party that this processing does not take place or if desired to be specified or changed conditions Pleggi can be contacted by email: info@pleggi.com or by any other way he deems fit.

4. Obligations of the Employer

4.1. Processed personal data will be only and only for a purpose recruitment, the future employment of workers or employees, as any information processed by the Employer in the Platform will aim for this. you are you agree to process personal data through the Platform only after a documented order from Pleggi, and this one is considered as such Agreement and any future correspondence related to it.

4.2. The employer is responsible for compliance with all requirements, which Pleggi assigns to him in connection with the protection of the personal data of Our users, whether we have requested them before or after consent you with this agreement. You do not have the right to store CVs (resumes) of the Users in your personal employer profile in The platform for a period longer than 6 months, unless the User does not unequivocally agreed to this by his express consent. Everyone else data are processed by the Employer for the period in which they are the User allowed or until their Platform account is deleted.

4.3. You undertake to provide and are fully responsible for respect and compliance with the requirements of Regulation (EU) 2016/679 (including all conditions under Article 28 of the regulation are considered inseparable part of this Agreement) and these Terms by its Representatives, contact persons and any other persons to whom they may be provided data about Users.

4.4. You undertake upon receipt of a request from Users in in connection with the exercise of their rights, to fulfill requests and/or return a reasoned answer within the terms provided for in accordance with Regulation (EU) 2016/679, as well as notify Pleggi of the Users' requests if they concern us directly or indirectly.

4.5. You undertake to provide up-to-date contact details of Users, regarding the protection of their personal data, including contact information with the Data Protection Officer (if applicable).

4.6. You undertake not to demand on any occasion from Users sending special categories of data within the meaning of Art. 9 and Art. 10 of Regulation (EU) 2016/679, through the Site. The site is not designed to collect, process and store such data. Such data is prohibited to be processed through the Platform.

5. Data Storage and Deletion By accepting these Terms, You and Pleggi agree (subject to whichever is applicable, only one or both):

5.1. The Site must have technological possibilities for processing of the data provided (including the data stored in your account) to personal data sent by Users to your account until it is deleted from Your side (by Your Representative), but not longer than 3 years from the date of posting the ad.

5.2. To delete the personal data of Users in your account after expiration of the term specified in item 5.1. (if not previously deleted by you, via use of the functionalities of the Site).

5.3. To ensure technological capability (functionality) on the Site - Users may remove their personal information from your account at any time data sent to them by you. Nevertheless, Users have no obligation to use the functionalities on the Site and have the right to to address their requests directly to you/us at any time.

5.4. Ensure automatic deletion of all personal data, located in your account, upon termination of your registration on the Site, except where prohibited by law. If you wish to save this data, it is necessary to do so before closing the account as long as it is legitimate.

5.5. Points 5.1. - 5.4. do not waive your and our obligation to review and promptly delete personal data for the processing of which you have no legal basis or the same has been lost.

5.6. not to store personal data outside of the Platform account if the relevant personal data is extracted from the Platform.

5.7. In case you want information about Users, via The platform to be used for future recruitment, you you must obtain the express consent for this from the relevant User. Pleggi is not responsible for the subsequent processing of information about Users from whom you have not obtained proper consent for processing.

6. Scope of assigned activities The scope of the processing activities assigned by Pleggi to the Employer, by accepting these terms and using the services, it is determined, as follows:

6.1. Purpose: providing the services in this Platform legally basis the express consent of all data subjects whose personal data are processed.

6.2. Data Subjects: Users who themselves have submitted their data to You, through the Platform on your employer profile, Representatives of Employer and contact persons.

6.3. Data: the information and documents contained in the sent to you data. Regarding the contact persons and Representatives - name, surname business, phone and email address, photo, and position/in what capacity they are your representatives/contact persons.

6.4. Object and nature: providing opportunities for establishment of compatibility for future employment relationships and to use functionalities for their review, storage, deletion, about The users. Regarding the Representatives and contact persons - personal contact with You, the possibility of providing all the functionalities of the Platform, including monitoring the activity of your representatives therein.

6.5. Term: for the term of this agreement between you and Pleggi, unless otherwise stated in these Terms or in the current legislation.

7. Security Pleggi and You undertake to:

7.1. You implement technical and organizational measures (with respect to staff, buildings, software, hardware, networks, servers, encryption, control, reporting and monitoring, vulnerability checks, etc.) to ensure level of protection against unauthorized or accidental access, loss, alteration, disclosure or destruction of data commensurate with the risks. These measures will be the same as in our Privacy and Cookie Policies, applicable to Users and the HR platform.

7.2. You ensure that all persons authorized by Pleggi or You to process personal data, have undertaken an obligation to observe confidentiality.

7.3. You do not disclose personal data of the Employer/Users to third parties parties in any way other than as provided in these Terms and the law cases.

8. Checks in connection with the processing of personal data

8.1. Pleggi undertakes to provide the necessary assistance for performing audits and checks from a competent supervisory authority regarding the personal data processing activities assigned by you.

8.2. Pleggi will periodically provide information on availability certificates, audits, etc. sub., in kind and to the extent that this does not endanger the security of the Services. In the event that in connection with your obligations under protection of personal data, additional checks are required, it is possible the assignment of an audit after the signing of a preliminary agreement with Pleggi, defining scope, term and chosen by mutual agreement accredited to carry out audits under Regulation (EU) 2016/679 person. When making one type of audit The employer undertakes to pay all fees, remunerations and costs for the activities and services performed, both by the auditee and and by Pleggi. The audit may be carried out only in a manner and to the extent which do not affect the obligations and rights of other users of The platform related to the protection of personal data.

9. Pleggi's notice The employer undertakes to notify us:

9.1. In the event of an inspection undertaken by a supervisory authority for the protection of personal data in connection with the processing of information about Users, entered into your account, except where prohibited by the law, as well as regarding the processing of data for the contact persons and yours Representatives;

9.2. In case it finds itself unable to perform your obligations under these Terms, for any reason;

9.3. Immediately (but no later than 48 hours after its establishment), c in the event that it detects a breach of information security regarding The users, information about which you store in your account, your Representatives and contact persons stored in your account, such as the notice will include: a description of the nature of the incident, including if possible, the categories and the approximate number of affected subjects of data and the categories and approximate quantity of affected records of personal data; description of possible consequences of the incident and description of measures taken or proposed to deal with the incident and/or mitigation of possible adverse consequences.

9.4. Pleggi will also notify you in similar situations if it finds this for necessary.

10. Assistance of Pleggi The Employer undertakes to us:

10.1. Provide assistance in proving the fulfillment of your obligations, related to the processing of personal data commissioned by you.

10.2. Assist in fulfilling your obligations to notification to the supervisory authority in the event of a security breach.

10.3. Assists, as far as possible and reasonably can be expected, through the functionalities of the Platform and through appropriate organizational and technical measures in the performance of your obligations to comply with requests to exercise the rights of the Users on your ads related to the protection of their personal data.

10.4. You assign, and Pleggi obligates, upon receipt of a request by a User in connection with the exercise of rights under Regulation (EU) 2016/679, related to received by you, to inform him that it is necessary to contact you directly at the contacts you specified. On that note, you you undertake to keep your contacts up-to-date at all times The site.

10.5. Pleggi will also assist you in similar situations if found this for necessary.

11. Responsibilities You are responsible for damages, arising from the processing carried out when you have not fulfilled the obligations under the Regulation, when you have acted outside of lawful instructions or c conflict with them. When and if we as Data Controller pay full or partial compensation for damage caused, we have the right to ask you to reimburse us some or all of the compensation paid, corresponding to the part of the responsibility for the damage caused that you have. If you fail to comply with this agreement, you assume full responsibility for the adverse consequences arising for Pleggi from your wrongdoing actions or omissions, including but not limited to financial.


1. Data Protection Pleggi will treat the Employer's data as confidential by processed only in connection with and to the extent necessary for the provision of services or other cases provided for in the Terms and Policies. Of course, Pleggi will process the same data, and according to its own policy, c in his capacity as Administrator of personal data.

2. Security Policies

2.1. When processing data, Pleggi will apply policies for security, consistent with the requirements of the law and good practices, with a goal ensuring confidentiality, integrity and availability of data.

2.2. In order to ensure effective protection, the policies will be reviewed regularly, and at least once a year will be carried out comprehensive review.

2.3. All Pleggi employees are required to apply these policies and practices in their work. Employees get to know each other promptly with any change, and in addition are required to review all policies at least once a year.

2.4. Pleggi will carry out checks when appointing new employees in within the framework of the law.

3. Security incidents

3.1. Pleggi will implement a plan that complies with all regulatory requirements to act on security-related incidents and in accordance with the notification requirements under the Regulation.

3.2. Pleggi will investigate all potential incident cases and will implement an action plan. In case the Employer suspects the presence of vulnerability or security incident, it is necessary to notify immediately Pleggi.

3.3. Pleggi will notify immediately (but no later than 48 hours from the knowledge) in the event of a breach of the security of the Employer's information and will provide, as far as possible, information about the incident and the actions taken.

4. Information systems and networks

4.1. Pleggi will keep the Employer's data logically separate from the data of other Employers.

4.2. Pleggi will apply encryption when transferring data over public networks, using technologies such as "hedging" and "encryption", SSL for protection of communication between you and the Platform. We protect access tokens, used by the Platform, which could contain information, sufficient to impersonate you, with public key cryptography with sufficiently large length, guaranteeing maximum security and impossibility to be read at least in the next 10 years.

4.3. Pleggi will implement solutions for key management, encryption and pseudonymization of stored data depending on the level of risk at the relevant activity.

4.4. When managing the access of its employees, Pleggi will give the minimum necessary rights to perform official duties or a specifically assigned task imposing the relevant access, only for the period, for which is necessary.

4. 5 Physical protection and access control: - Pleggi will use colocation centers with physical access control. - Pleggi will control access to its offices by admitting only authorized persons and persons with an authorized companion. Pleggi will apply technical measures.

5. Security, Continuity and Availability

5.1. Pleggi will conduct automated and/or manual penetration testing and vulnerability periodically and when implementing new or changing existing applications, systems and networks.

5.2. Pleggi will maintain risk management policies and procedures upon changes. Before implementing changes to applications, systems and networks, they will be documented in a change request including a description, reason for the change, timeline, expected outcome, rollback plan, and documented approval from an authorized person.

5.3. Pleggi will maintain a list of information systems associated with provision of the Services and will monitor their status.

5.4. Pleggi will ensure backup of the Employer's data, such as ensure that at least one copy is kept separate from the main system. Archives will be stored in encrypted form. Pleggi will perform tests for their condition and ability to be restored.

5.5. In addition, Pleggi undertakes to implement organizational and technical measures according to the recommendations and opinions of the CPLD.

Effective date: 12/20/2020

Last modified: 12/12/2022