Rentables24- Privacy Policy

This version was created in November 2024

We care about your privacy and are committed to protecting your personal data. This privacy policy will inform you how we process your personal data, your privacy rights and how the law protects you. Please read this privacy policy carefully before using our Services.

Content

1. Who are we?
2. What data do we collect about you?
3. Do we collect data from children?
4. Why do we process your personal information?
5. Data Processing as part of OLX Developer Portal Services
6. Data processing as part of the services in the “Work” Category on OLX
7. How will we notify you of changes to our privacy policy?
8. Your rights
9. Communication and Marketing
10. Who do we share your data with?
11. International transfer of personal data
12. Where do we store your data and for what period?
13. Technical and organizational security measures for processing
14. Links to Third Party Websites
15. Contacts
16. Data protection

This privacy policy applies to your use of any products, services, content, features, technologies or functions and any related websites, mobile applications, mobile sites or other online properties or applications offered to you by us (collectively, the ” Services “).

1. Who are we?  up

The primary controller of your data for the purposes of our international services is OLX Global BV, a limited liability company with registered office at Gustav Mahlerplein 5, Symphony Offices, 1082 MS Amsterdam, The Netherlands. OLX Global BV is the parent company of OLX, which provides you with our Services under our  Terms and Conditions  (hereinafter referred to as ” Rentables24″, ” we ” or ” our”  in this privacy policy). This OLX company is also considered a data controller for the local services it offers. The relevant contact details are set out in section 5.

The local data controller is:  “Atlas Effect” EOOD , a company registered and registered in the Republic of Bulgaria with EIK 204784306 and registered office and address in Sofia, PK 1000, ul Konstantin Irechek 48.

2. What data do we collect about you?  up

2.1.1.  Data provided through direct interaction

Registration and other account information

When you register to use our Services, we may collect the following information about you:

• if you register directly on our platform, you will be asked to provide your email address;
• if you sign up using your Google Account: first name, last name and email address and the URL to your Google profile picture;
• if you register using your Facebook account: first and last name as they appear on your Facebook account, the email address associated with your Facebook account, your Facebook ID, and the URL of your Facebook profile picture. In the event that you have provided permission to Facebook through their in-app privacy option (which appears immediately before you register for our Services), we may collect your gender, age or email address depending on the permissions you have provided; 
• if you sign up using your Apple ID account: your first name, last name, and email address; You can decide whether to share your email address with us when you sign in to your Apple ID account.

and

Depending on the choices you make while logging into our Services or during the process of engaging with our Services, you may choose to provide the following additional personal data:

• your name;
• email address;
• mobile number;
• Your payment details, in case you wish to use our paid services, as defined in  the Terms of Use , which depending on the payment method used include: details of
  • your credit card (cardholder name, card expiration date, credit card type and the last four digits of your credit card number);
  • your mobile number;
  • Your e-mail.
• data regarding studies, work experience, skills, photos, preferences regarding the desired job, as well as any other information included in your CV or submitted directly by your employers through our Services, when you choose to provide us with this data through the “My CV” function “in your OLX account settings to apply for one of the jobs posted under the Jobs tab.

Verifying your OLX account 

We verify OLX user accounts using SMS verification to ensure that each account is associated with a real and unique user. This validation process begins after you proceed to publish your first listing on our Services. To verify your OLX account before posting your ad, we will send you an SMS to a valid mobile number provided by you. This process is completely free.

If you do not agree to verify your account, it will remain active and you will be able to use our services with limited functionality. This limited functionality of an account means that you cannot post new advertisements or edit, update, promote, expand, activate, deactivate or delete existing advertisement listings until your account is verified via SMS. You will also not be able to receive or reply to messages from other users.

Each user can request a maximum of 5 SMS messages with verification codes within 24 hours. Account validation is done only once for each account until successfully verified via SMS by the user.

Once you verify your OLX account, it will remain linked to the mobile number used for SMS verification. If you want to change the mobile number associated with your OLX account, you will need to contact our customer support team using the  contact form .

Communication through the chat feature on our Services

When you use our chat feature to communicate with other users, we collect and process the content and information you choose to make available to other users through that feature.

When you contact us through our Help Chat, you may communicate with a chatbot, an OLX team member, or an individual who is a user like you, has been selected and verified by OLX to assist you, as in any of the three options you will be notified who you are talking to right at the beginning of the conversation.

Recording telephone conversations with our customers and sales teams

When you call or choose to be called by one of our customer service representatives or our sales team, we record the call, subject to your express consent, in order to improve our customer interaction practices.

Audio and video recording for specific customer interaction surveys

When you expressly agree to participate in customer interaction surveys organized by OLX from time to time, we will record the interaction with our team. For each survey organized by OLX, we will provide you with specific information about how we process your personal data and the purpose for which we do so.

Participation in our user surveys

We will occasionally provide you with our user surveys to measure your overall satisfaction with the quality of our services. For this purpose, we will only use a session (this is a random identifier assigned to you when you download our mobile application or visit our website). You may also choose to provide us with your contact details, such as email and mobile number, upon our request to contact you and invite you to attend one of our user experience (UX) tests or an interview with our team. Please note that the information you provide to us in connection with our survey questions may at times contain personal information voluntarily provided by you in your responses.

Rating and feedback

We collect information about the rating and ratings you give other users as a result of interacting with them, but also about the ratings you receive from other users, in order to measure user satisfaction with the transaction experience and to ensure an optimal and effective level of communication between users, as well as to check and prevent inappropriate actions and behavior in the context of the activity carried out in connection with our services, this information allows us to take the necessary and appropriate measures to maintain high standards in providing our services.

2.1.2.  Information we collect automatically when you use our Services

When you use our Services, we automatically collect the following information about you: Information about

the device

• We collect device-specific information such as operating system version, unique identifiers. For example, the name of the mobile network you use, your IP address, your device’s language settings, device brand and type, device operating system and version, browser type and version, and device-specific software information such as fonts, system and browser time zone, available video and audio formats. If you are signed in, we associate device IDs with your OLX account.

Location information

• Depending on your device’s permissions, if you post an item to our Services, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and cell towers. Your location data allows you to see user items near you and helps you post items to your location. In the event that we need your location data, we will first show you a pop-up window asking you to choose whether or not to allow us access to your location data. If you do not allow us access to your location data, you will still be able to use our Services, but with limited functionality. If you do allow us access to your location data, you can always change this later by going to the settings on our website or mobile app and disabling the permissions related to location sharing. To learn more about the purposes for which your location data is used and how this data is processed, please refer to section 4.2 (ii) of this Privacy Policy.

Customer and log data

• Technical details, including your device’s Internet Protocol (IP) address, time zone, and operating system. We will also store your login information (date of registration, date of last password change, date of last successful login), your browser type and version.

Clickstream data

• We collect information about your activity on our Services, which includes the sites from which you accessed our Services, the date and time stamp of each visit, the searches you performed, the advertising listings or banner ads you clicked on, your interaction with such advertisements or advertisement listings, duration of your visit and the order in which you visit the content on our services.

“Cookies” and similar technologies

We use cookies to manage our users’ sessions, store your preferred language selection, and provide you with relevant advertisements. ” Cookies ” are small text files transferred from a web server to your device’s hard drive. Cookies can be used to collect the date and time of your visit, your browsing history, your preferences and your username. You can set your browser to refuse all or some cookies or to warn you when websites set or access cookies. If you disable or decline cookies, please note that some parts of our services may become unavailable or may not function properly. For more information about the cookies we use, please see our  Cookies and Similar Technologies Policy . In Section 10, you will find more information about how we share this information with analytics service providers and advertising partners.

2.1.3.  Data from third parties or publicly available sources

We receive personal data about you from various third parties and public sources, which we may combine or link with the personal data we collect from you through our Services. In particular, this includes the following information:

1. if you register using your Google account: we receive the email address associated with your Google account (to create your OLX account and send you system notifications and marketing messages), your Google ID and your full name (used as your username when using our Services) and your profile picture URL (to create a profile picture for your OLX account);
2. if you register with your Facebook account: we receive the email address associated with your Facebook account (to create your OLX account and send you system notifications and marketing messages) and your public profile information, including your Facebook ID, own and last name (used as your username when using our Services) and the URL of your Facebook profile picture (to create a profile picture for your OLX account);
3. Certain technical information and information about the use by analytics providers, such as Google Analytics 360, for statistical purposes and to analyze the use of our Services, to improve our Services and for online marketing (more on this in Section 10);
4. if you choose to store your payment card data with us, we receive the following data related to your card from our payment partners, such as EPay: first and last name, card expiration date, last four digits of the card number;
5. government authorities provide us with a username, phone number and email when they ask OLX to carry out checks or provide these authorities with more data in the context of fraud prevention activities.
6. rating and feedback: if you use our Website as a seller, we collect and provide information about the rating and feedback you have received from other users after your interactions with them, in accordance with our Terms and Conditions. This is part of our services aimed at measuring users’ satisfaction with their transaction experience and to ensure an optimal and effective level of communication between users, as well as to check and prevent inappropriate actions and behavior in context of the activity carried out on our Website, this information allows us to take the necessary and appropriate measures to maintain high standards in the provision of our services.
7. Do we collect data from children?  up

Our Services are not intended for children under the age of 16 and we do not knowingly collect data from persons under the age of 16. If we learn that a person under the age of 16 has provided us with personal data, we will delete it immediately.

4. Why do we process your personal information?  up

We will only use your personal data where the law allows us to. We will most often use your personal data in the following circumstances:

• When we need to fulfill a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests and we believe that our legitimate interests are not superseded by your or other data subjects’ interests or fundamental rights and freedoms, for example to improve our services and to make our services safe and secure.
• Where we must comply with a legal or regulatory obligation.

In certain circumstances, we may also process your personal data based on your consent. If we do this, we will notify you of the purpose and category of personal data that will be processed at the time we seek your consent.

Below we have set out a description of the reasons why we use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where relevant.

4.1  To provide access and provide services

1. If you log in with your mobile number or email ID, we use your first and last name, mobile number and/or email address to identify you as a user and provide access to our services.
2. If you sign in with your Facebook account or your Google account or your Apple ID account, we use your first and last name and your email address on such account, as well as the URL of your profile picture (except when you use Apple Account ID) to identify you as a user of our Services and to provide you with access to our Services. The above login details are also used by us to deliver our Services to you in accordance with our  Terms of Use .
3. We use third-party payment service providers to process any payment you make for our Services. Depending on the payment method, you may be asked to provide us with your payment and credit card details, which we will then provide to the payment service provider to process your payment. We do not store your credit card information unless you choose to save such information to facilitate periodic payments without having to re-enter your details each time. In such cases, we only store your cardholder name, card expiry date, card type and the last four digits of the card number. We do not store any credit card code verification values ​​and simply forward such values ​​and your credit card number in an encrypted manner for the purpose of processing your payment by our payment service provider.
4. We store your data regarding your education, professional experience, skills, photos, preferences regarding the desired job, as well as any other information included in your CV or submitted directly by your employers through the Services, in order to facilitate your direct communication and transmission of such data of employers who publish job advertisements in the “Work” category. The legal basis for this processing is the conclusion and performance of the contract between OLX and you under which OLX may provide its services to you in relation to the Jobs category.

We process the above information for the adequate performance of our contract with you.

4.2  To improve your experience with our Services

1. We use clickstream data to:

• offer you tailored content, such as to give you more relevant search results when you use our services, to
• to determine how much time you spend on our Services and how you navigate through our Services to understand your interests and improve our Services based on this data. For example, we may provide you with suggestions for content to visit based on the content you clicked on.

      2. If you choose to provide us with your location data, we use your location data for the following purposes: to

• to compile anonymous and aggregate information about the characteristics and behavior of OLX users, including for the purposes of business analysis, segmentation and development of anonymous profiles.
• to improve the performance of our Services and to personalize the content we direct to you. For example – using location data, we show ad listings that are near you to improve your shopping experience. For this purpose, the Google Maps service is integrated into our Services. Google Maps is provided by us and Google acting as independent controllers. This means that both Google and us are responsible for the processing of your location data in the context of Google Maps. In any case, we will not process your location data for purposes other than those explained in this privacy policy. However, Google may process such location data for its own purposes, as explained in Google’s Privacy Policy, which can be viewed  here . Use of Google Maps through our Services is subject to the Google Maps – Google Maps/Google Earth Terms and Conditions .

      3. Using the contact information in your account, which includes your email and mobile number, we map the different devices (such as desktop, mobile, tablet) that you use to access our services. This allows us to correlate your activity on our Services across devices and helps us provide you with a seamless experience no matter what device you use.

      4. We use the images you upload, descriptions and prices you provide in your ad listings to train machine learning models to personalize search results in relation to ad ranking and user interest, to improve the identification and presentation of advertising elements, to improve the search function and increase the probability of a successful sale. This helps us improve our Services and provide you with a better user experience.

      5. To display and recommend lists of advertisements on our Services that may be of interest to you, we use algorithms that use information related to your browsing behavior, items you have purchased, clickstream data, your user ID and your location data if you have given us permission to use this. We use this form of automated decision-making based on our legitimate interest in improving our Services and providing a better user experience by offering you more relevant advertising lists.

      6. We access and analyze your chat messages with other users conducted through the chat feature on our Services to improve the product and to provide you with a better user experience (for example, to identify sold items and only provide active advertising lists). That’s why we develop and train machine learning models and algorithms to automatically analyze your chat content. To build and train our machine learning models, our machine learning experts can review sample chat content manually. In these circumstances, highly restrictive access rights apply to selected machine learning specialists analyzing the chat content. During this analysis process, we de-identify chat content as much as possible by applying a scanning filter to detect and hide personal data such as names, phone numbers, email addresses. However, there may be instances beyond our control where chat content may display certain personal data that you have chosen to provide.

      7. Using your session continuously (a random identifier assigned to you when you download our mobile application or visit our website), we will from time to time provide you with user surveys designed to determine your satisfaction with the quality of our services. When we provide you with a survey, we may also ask for your email or mobile number to contact and invite you to attend one of our user experience (UX) tests or an interview with our team.

      8. To measure user satisfaction regarding their transaction experience and to ensure an optimal and effective level of communication between users, as well as to check and prevent inappropriate actions and behavior in the context of the activity carried out on our Website , we collect rating and feedback information exchanged between users of our Website, this information allows us to take necessary and appropriate measures to maintain high standards in the provision of our Services.

We process the above information for the adequate performance of our contract with you and based on our legitimate interest in improving your experience with our services.

4.3  To provide you with safe and secure services

1. We use your mobile number, log data and unique device identifiers to administer and secure our services (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and data hosting ).
2. We access and analyze your chat messages with other users conducted through the chat feature on our Services for customer satisfaction, safety and to prevent fraud (for example, to block spam or abusive messages that may have been sent to you from other users). That’s why we develop and train machine learning models and algorithms that help us automatically detect and prevent inappropriate and fraudulent user behavior. During the analysis and training process, we de-identify chat content as much as possible by anonymizing unique identifiers assigned to users. However, there may be instances beyond our control where chat content may display certain personal data that you have chosen to provide. Only in limited cases and circumstances do our customer safety and security specialists manually review chat content, for example if we have strong indications leading to an urgent suspicion of fraudulent activity. In these circumstances, highly restrictive access rights apply to selected customer safety and security professionals analyzing chat content.
3. To prevent and detect fraud with our Services, we use algorithms that recognize suspicious or fraudulent user behavior based on certain information such as user activity and posted content, which may result in certain user accounts being banned. Automatic banning occurs when there is a very high degree of certainty that an account or activity is fraudulent. Otherwise, human review is performed by selected customer safety and security professionals based on highly restrictive access rights. We use this form of automated decision-making based on our legitimate interest in detecting and preventing fraud and keeping our Services safe and secure for our users. If you believe that your account has been wrongfully banned, you can contact us via our  contact form  , in which case our team will review the decision to ban your account.
4. We collect certain information from and in connection with the electronic device from which you access our Services based on our legitimate interest in preventing fraud with our Services. The information we collect includes your user ID (depending on whether you are logged in), country OLX domain, IP address, device language settings, device brand and type, device operating system and version, type and version browser and device-specific software information such as fonts, system and browser time zone, available video and audio formats. Device-related information is used to determine whether the same device is being used when users interact with our Services. We associate such information with a fraud score of the user, based on which we may ban certain users. For more information on this, please refer to our  Policy on Cookies and Similar Technologies .  If you believe that your account has been wrongfully banned, you can contact us via our  contact form  , in which case our team will review the decision to ban your account.

We process the above information for the adequate performance of our contract with you and based on our legitimate interest in preventing fraud and improving the overall quality and efficiency of our Services.

4.4  To promote and offer you services that may be of interest to you

1. We use your email address and mobile number (via SMS or Viber) to make suggestions and recommendations about our services that may be of interest to you.
2. To send you email messages, to make suggestions and recommendations about ad lists or about our Services, we use algorithms that use information based on your click data. We will always provide you with the opportunity to opt out of such communications by including an unsubscribe link. We use this form of automated decision-making based on our legitimate interest in improving our Services, increasing the number of transactions on our Services and providing a better user experience by offering you more relevant advertising lists.
3. We use clickstream data to monitor and report campaign delivery performance to our business partners and for internal business analysis.
4. If you choose to provide us with your location data, we may use your location data to measure and monitor your interaction with third-party advertising banners that we place on our Services.

We process the above information based on our legitimate interest in undertaking marketing activities to offer you Services that may be of interest to you. In particular, you may receive certain marketing communications from us:

• through any preferred means of communication if you have requested such information from us;
• by email, about similar products and services if you already use our Services or have acquired some of our products;
• by phone or email if you have provided us with your details when you entered a competition; or
• by phone or email if you signed up for a promotion.

You can ask us to stop sending you such marketing communication at any time by clicking the opt-out link in the email sent to you or by changing the notification settings in your account.

In other cases, apart from those mentioned above, we will only use your email and mobile number to send you direct marketing communications (via email, push notifications, SMS / Viber or phone calls) if you have given us your consent to do so by checking the relevant box when registering in our Services. You can always change your mind and withdraw your consent in the notification settings of your OLX account.

In case you have problems changing your notification settings, please contact us via our  contact form .

4.5  To provide you with a quality customer support service

1. We record your telephone conversations with members of the customer support team or members of the sales team, only with your express consent;
2. We have access to the personal data you share with us through chat messages through our Help Center and may share it with our partners (other users who have been selected and verified by OLX) who assist us to provide a better customer support service.
3. If you agree to participate in customer interaction surveys organized by OLX from time to time, we will record your interaction with our team to improve our Services.

We process the above personal data to further analyze your interaction with our customer relations team, with our partners or sales team members (as applicable) and to improve the way our team members serve users.

You can withdraw your consent at any time and free of charge by using our  contact form .

5. Data Processing as part of OLX Developer Portal Services  Upstream

OLX Developer Portal The OLX Developer Portal is a tool addressed to individuals or legal entities who would like to publish their advertisements on our Services.

In order to provide OLX API services as part of the OLX Developer Portal, we process the personal data of our users who are software developers or individual contractors / employees of such developers (collectively “ Developer ” or “ Developers ”). For this particular service, we process: the name, first and last name of the contact person with the developer, and the corresponding phone number.

Using OLX API services requires activation with OLX account details. Whenever a new application (the “ Application ”) is added by a developer, you are required to fill out a special form and provide us with additional information related to the application and a contact person in accordance with the provisions of the  OLX Developer Portal Terms and Conditions . Providing the data required in the form is purely voluntary, however, it is necessary to use the OLX API service. As part of using the OLX API services, we also process developer activity data as part of the OLX website.

We process the above information for the proper performance of the contract you have entered into with us, improving our Services and based on the premise of our legitimate interest in preventing fraud or abuse.

OLX is not responsible for the lawfulness of the processing of users’ personal data as part of the application added by the developer. The obligation to provide reliable information about the rules of use of the Application, the security policy and other information required by the applicable legislation, in particular the regulations on the protection of personal data, is on each developer. OLX makes it mandatory for developers to update and maintain the Application, in particular to ensure the security of user data processed through it.

In order to exercise their rights under the provisions on the protection of personal data, any user who uses the Application must contact the Developer directly or the person indicated in the relevant document describing the rules for using the particular Application.

6. Data processing as part of the services in the “Work” Category in OLX  up  

6.1 Processing of personal data in the recruitment process by employers 

In order to facilitate the process of communication regarding job postings included in the Job Category, we have made it possible for our users (referred to below in this section as “Candidate” or plural “Candidates”) to add, store and use their resumes on our Website. Applicants can save their CV in the process of responding to a specific job posting, as well as through their profile settings – the Add CV section (which can also be accessed through Settings and selecting the Your CV section). Only one resume document can be uploaded to your account at a time. Changing or adding a resume document during the application process through the form provided on the Platform will add or change it to your account. Depending on the functionalities available on the Platform in the job application process, your resume document may be automatically attached to the job application you submit, which will be generated each time from the application submission form on the Platform. You retain control over the submission of your CV document to the Employer ie. even if this document is automatically attached to your application according to the conditions described in the previous sentence, you can always opt out of attaching your CV to a particular application using the functionalities provided in the form. You can manage your CVs saved in your OLX profile by adding or removing individual files in the Applicant Profile – CV Section and through the special button in the process of submitting an application through the form. Once your resume is saved to your profile (“Applicant Profile”), you will not need to attach a separate file each time you apply to a job posting.

The resume is visible in the Candidate’s profile until it is removed by the user, but no longer than the moment the profile is deleted.

The resume and all other data provided to the selected employer or stored through the Website will be processed by the employer’s profile for four (4) months from the moment of receipt, regardless of whether the Applicant’s profile is deleted or not. The above does not apply to the applicant profile service within the scope specified in clause 3.8.2 of Appendix 1 to our General Terms and Conditions. In this case, the link to the applicant’s form content is active as long as this service is enabled in the applicant’s profile.

When the Applicant provides his/her personal data to a selected employer, the latter becomes a separate controller of such personal data for recruitment purposes and possibly for other purposes determined by the employer. In this way, the employer can keep the applicant’s data outside of the employer profile and store it for a separate period of time outside of our Website.

Therefore, OLX, as the controller of personal data, is only responsible for the processing of the applicant’s data as part of the services of the Website.

As part of the “Application” section of our Website, it is possible to complete an applicant form, as part of which you voluntarily provide your personal data such as name and surname, contact details, education, work experience, skills and interests.

We store this data in order to provide our Services, in accordance with your decision, until you delete it and no longer than when the applicant’s profile is deleted. Once you have completed at least 75% of the applicant form, we automatically activate the “Applicant Profile” service described in Appendix 1 of our Terms and Conditions to display personalized ads to the applicant in the “Job” category. This service includes an automatic analysis of the data you provide and recommends ads suitable for you.

This service is based on profiling using your personal data. For this purpose, we will profile your data contained in the application form and in the “Your new job” section until you opt out of this service or stop using it in accordance with our Terms and Conditions. Profiling is necessary for the purpose of performing the “Candidate Profile” service. However, this will not result in automated decision-making that may have legal consequences for you or otherwise significantly affect you – You will continue to have access to the full range of job postings and the referrals we receive are only and exclusively offers which, based on the evaluation of the data contained in your application form and the section “Your new job”, we consider potentially interesting for you. Employers have no influence on and are not informed of the referrals you receive. 

On the website – in the “Application” section – it is possible to fill out a candidate profile in which you voluntarily provide personal data such as name, date of birth, contact details, education and professional experience, as well as skills and interests. We retain this data to provide you with our services, at your discretion, until you delete it, but no longer than when you delete your Account.

When the User fills in two of the parts with information in the section Application – Recommended offers and ads or Your new job: preferred workplace location and preferred profession, as well as in case of active use of the Service (including by viewing the content of the ads selected by the User , adding them to Favorite ads, finding the phone number or message box of the person who posted the ad, sending an application, as well as pressing the Ask a Question button), the Recommended Offers and Ads service, as well is described in point 3.7.3 of Appendix 1 to the General Terms and Conditions, in which the User is automatically shown ads that are recommended and match his interests, which, according to the OLX tool, are most suitable for the User’s profile and preferences, will be activated automatically . In the case of filling in the preferred workplace location and the preferred occupation, the advertisements will be selected based on the data so provided, and in the case of active use of the Service, as described in the preceding sentence, also based on the data related to this use. The Recommended Offers and Ads service is provided to Visitors and when they actively use the Service, including by viewing the content of the ads selected by the Visitor, they discover the phone number of the person who posted the ad or his message box. This Service includes automatic analysis of the data you have provided and data related to your use of the Service and recommending advertisements relevant to them on that basis. This service is based on profiling your personal data. We will profile your data contained in the Your New Job form and Featured Offers and Ads and related to your use of the Service and in the Your New Job tab for this purpose until you opt out of this Service as described in point 3.9.2 of Appendix 1 to the General Terms and Conditions, or until the service is terminated in accordance with the General Terms and Conditions. This profiling is necessary for the proper performance of the “Recommended Offers and Ads” service, but will not result in automated decision-making that may give rise to legal consequences for you or similarly materially affect you – You continue to have access to the full job listings catalog, and the recommendations you receive from us are only suggestions based on a review of the information you provide in the “Your New Job” and “Recommended Offers and Listings” sections, as well as information related to with your active use of the Service, may be of interest to you. Employers have no influence on and are not informed of the referrals you receive.

When you respond to an advertisement in the Job category through the means of communication provided by OLX, you will be asked, in addition to the applicant’s CV, message or form, to provide selected data necessary to transfer your application to the employer. You can save this data in your Candidate Profile as part of the application form and thus use it for future applications. The provision of the above data is necessary in order to use the service to respond to advertisements in the “Job” category as part of our Website. OLX processes this data to provide the specified service in accordance with the General Terms and Conditions of the Website.

6.2 How do we transfer your data?

Responding to a specific job advertisement in the “Job” category implies the provision of your personal data to the employer at your request. After sending a response to an advertisement, the employer receives a message which, according to your choice, settings or scope of the service, may contain your personal data (e.g. in the form of an attached CV or a link to the candidate form in accordance with the “Candidate Profile” service ) and will be able to include your application in the recruitment process. Remember that when you make your CV available to the employer, he becomes an independent controller and may also process your data outside our Website, in particular outside the rules set by OLX. We advise you to carefully read the content of the advertisements in the “Job” category and the rules for the processing of personal data specified by the employers in their respective privacy policies.

You share your personal data and other information with employers based on your own, informed and conscious decision. Before providing your data, you should carefully consider the risks associated with disclosing your personal data, in particular your address, contact details or exact location. Such risks can be, for example, the possibility of being identified by others involved in the recruitment process, loss of some privacy and, in the last case, even identity theft.

7. How will we notify you of changes to our Privacy Policy?  up

We may amend and update this privacy policy from time to time. We will notify you of material changes to this privacy policy, as appropriate and as required by applicable law, for example by posting a prominent notice within our Services or sending a message through our Services or sending you an email. If you do not agree with the way we process your personal data and the choices we provide you, you can close your account at any time by going to your account settings and choosing to delete the account.

8. Your rights  up

In certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please go to your account / privacy settings or contact us using our  Help Center :

• Right to request access  to your personal data (known as a “data subject access request”). This allows you to obtain a copy of the personal data we hold about you and to check whether we are processing it lawfully.
• Right to request correction  of any of the data we hold about you. This allows you to correct incomplete or inaccurate data we hold about you, although we may need to check the accuracy of new data you provide to us.
• Right to request restriction of processing  of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) where our use of data is unlawful; (c) when you need us to store the data, even if we no longer need it because you need it to establish, exercise or defend legal claims; or (d) you have objected to us using your data, but we need to check whether we have compelling legal grounds to use it.
• Right to request erasure  of your personal data. This allows you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to delete your personal data data to comply with local law. Please note that for certain purposes we may be legally required to retain your data. Please also see section 11.
• Right to object  to the processing of your personal data where we rely on a legitimate interest (or those of a third party) and there is something in your particular situation that makes you want to object to the processing on that ground because you feel that this affects your fundamental rights and freedoms. In some cases, we can demonstrate that we have compelling legal grounds to process your information that supersede your rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. You can exercise your right to object in the following ways, depending on the processing activity you want us to stop:

• for marketing emails, click on the unsubscribe link in our emails;
• for SMS / Viber marketing, push notifications or phone calls, change your notification settings in your account to opt out;
• for cookies, click “opt out” on our consent management platform and
• for any objection to the processing of your data in general, you can contact us via  the Contact Form .

• Right to request the transfer  of your personal data to you or to a third party. We will provide you or a third party you have chosen with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you have initially given consent for us to use or where we have used the information to perform a contract with you.
• Right to withdraw your consent to the processing of your personal data at any time. This does not affect the lawfulness of any processing we have already carried out based on prior consent.

No fee is usually required:  You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unreasonable, repetitive or excessive. Alternatively, we may refuse to fulfill your request in these circumstances.

Response time:  We try to respond to all legitimate requests within one month. Sometimes it may take us more than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

You also have the right to lodge a complaint at any time with the data protection authority responsible for you as set out in section 13.

However, before making a complaint to the data protection authority, we would appreciate the opportunity to address your concerns in the first instance, please contact our Privacy Office using our  contact form .

9. Communication and marketing  up

We will communicate with you by email, SMS or in an application notification in connection with our Services to verify your account with us, to inform you in the event that your listing has become active / expired and for other transactional communications in connection with our services. Because it is imperative for us to provide you with such transactional communications, you may not be able to opt out of such communications.

10. Who do we share your data with?  up

We may need to share your personal data with the parties listed below for the purposes set out in section 4 above.

Third Party Service Providers  : We use third party service providers to help us provide certain aspects of our Services and to maintain and monitor our Services. In this context, your personal data may be shared with the following recipients or categories of recipients:

• payment service providers, such as EPay or PayPal, may receive your personal data for the purposes of processing payments you wish to make through our Services; to make payments in connection with our services, regardless of whether it is a card payment or a payment with a payment order, we use EPay AD, registered in the Republic of Bulgaria with registered office and management address Sofia 1000, 16 “Ivan Vazov” St., registered in the Commercial register under EIK 131409398 (” EPay “), mandate of OLX processor to carry out these operations in accordance with Bulgarian legislation. You can learn more about how we work with EPay to process payments in section 11 of  the Terms and Conditions . We also use PayPal (Europe) S.à.rl, et Cie, SCA, 22-24 Boulevard Royal L-2449, Luxembourg (” PayPal “), which operates under the following  General Terms and Conditions ;
• Courier companies may receive your personal data in order to perform the “OLX Delivery” service. Your data will be transferred to Innoship Technology SRL, which provides the integrated service that helps you send your shipment for the purpose of performing the “OLX Delivery” service. As part of the cooperation, Innoship Technology SRL will also be responsible for providing your data to the selected courier responsible for the respective shipment. Transferred data includes: first name, last name, addresses, postal codes, cities, email addresses, telephone numbers, date and time of delivery, tracking number, signature and information about your session on our website. Within the scope of the purposes of performing the “OLX Delivery” service, Innoship Technology SRL and the courier companies are separate administrators of this personal data; the rules regarding the processing of users’ personal data by Innoship Technology SRL can be found in their Privacy Policy, available here.
• cloud service providers such as  Amazon Web Services, Inc.  (AWS),  Google Ireland Limited  (Google Cloud),  Microsoft Corporation  (Microsoft Azure), which may receive some of your personal data for cloud storage purposes;
• integrated third-party tool providers, such as  Google Ireland Limited  (Google Maps), which may receive your location data in order to improve the performance of our Services and to personalize the content we direct to you;
• vendors of customer support tools such as  Zendesk, Inc. , which may receive some of your data, such as user account details, customer service requests, message content, for the purpose of communicating with and supporting our customers;
• providers of customer relationship management tools, such as  SFDC Ireland Limited  (Salesforce), who may receive some of your data, such as user account data, sales lead contact data for processing by our sales teams ;
• marketing communication service providers, such as  The Smarts  or  RTB House , who may receive some of your data for the purpose of organizing and conducting marketing communication campaigns.
• Marketing communication service providers such as Intercom may receive some of your data for the purpose of organizing and developing marketing communication campaigns.
• Service providers such as GUURU that assist platforms to perform the services related to servicing contact centers with the help of private product experts registered and verified by these platforms may access data shared by you through chat on The OLX Help Center, in order to be able to assist you with any queries related to the use of our services and platform.

These third party service providers may be located in or outside the EEA.

We carry out checks on our third party suppliers and require them to respect the security of your personal data and treat it in accordance with the law. We do not allow them to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.

Advertising and Analytics Providers:  To improve our Services, we will sometimes share your information with analytics providers, such as Google Analytics 360, who (i) help us analyze how people use our Services in order to improve our Services and (ii) to help us with online marketing and interest-based advertising. For the most part, we share your information with them in de-identified form to monitor and report campaign delivery performance to our business partners and for internal business analysis. This information typically includes a cookie identifier, (abbreviated) IP address, referring URL, as well as browser and device information. By analyzing your browsing behavior on our Services through cookies with the help of analytics providers, we are able to better understand the use of our Services and improve our product and will be able to show you more relevant OLX ads when visit other websites. For advertising purposes, we partner with advertising vendors that are organized by the Interactive Advertising Bureau (IAB) and listed here:  https://iabeurope.eu/vendor-list/ . We may share with our advertising partners your cookie identifier (first-party and third-party cookies), which allows us to show you more relevant third-party ads on our Services based on your browsing behavior outside of our Services. To control and manage your ad settings, you can access the settings via a link in the footer of our website. For more details about our advertisers and analytics providers, please see our  Cookies and Similar Technologies Policy .

OLX Group Companies:  We will sometimes share your information with other “ OLX Group Companies ”, which means legal entities or subsidiaries directly or indirectly controlled by OLX Global BV where OLX Global BV holds more than 50% of the voting rights or has the right to control the site (entirely ” OLX Group “). The OLX Group consists of companies and subsidiaries worldwide. Many of these subsidiaries provide you with a wide variety of classifieds services in many different countries. You can view all of our ad brands under which we provide our services at  https://www.olxgroup.com/brands . For certain business operations, we leverage our global expertise by leveraging shared resources across subsidiaries to provide you with the best possible services, including product enhancements, customer support, security and safety, and business intelligence activities. This means that we may need to share your personal data within the OLX group of companies located both within and outside the European Economic Area (” EEA “).

Any sharing of personal data between OLX Group companies will always be subject to safeguards as described in Section 10, which we have shown in an internal data transfer agreement between all OLX Group companies. Such an agreement clearly defines the rights and obligations of all OLX Group companies to provide appropriate technical and organizational measures to protect your personal data.

Mergers and acquisitions:  If (part of) our business or our assets are reorganized, sold, transferred or merged with another business, your personal data will be disclosed and transferred to the new owners of the business. In such cases, we will take any action required by law, which may include notifying you and providing you with a choice as to whether you wish to continue using our Services.

Law enforcement authorities, regulatory authorities and others:  We may disclose your personal data to law enforcement authorities, regulatory authorities, governmental or public authorities and other relevant third parties in order to comply with any legal or regulatory requirements.

Publicly Available Information : When you post an item for sale using our Website, you may choose to make certain personal information visible to other OLX users. This may include your first name, last name, your email address, your location and your contact number. Some information, such as your rating and feedback received from other users, may automatically be publicly disclosed when an ad is posted. We also make your rating and feedback, along with your username, public to the users you rated. Please note that any information you provide to other users may always be shared by them with others, so please use appropriate judgment in this regard.

Customers, legal entities acting on our Services as employers : to provide you with our services related to the “Job” category and to facilitate the submission of your CV directly through our Services, when you wish to apply for a job posted on OLX Jobs, we will send employers data about studies, work experience, skills, photographs, preferences in relation to the desired job, and any other information included in your CV or submitted directly by you to employers through the use of our Services.

11. International upward transfer of personal data 

Whenever we transfer your personal data outside the EEA, we ensure that it is afforded a similar level of protection by ensuring that at least one of the following safeguards is in place:

• We will only transfer personal data to countries that have been deemed to offer an adequate level of personal data protection by the European Commission. For more details, see  European Commission: Adequacy of personal data protection in non-EU countries .
• When we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection as it has in Europe. For more details, see  European Commission: Sample contracts for the transfer of personal data to third countries .

You can obtain a copy of the relevant and implemented security measures by contacting us via  the contact form .

12. Where do we store your data and for what period?  up

The data we collect about you will be stored and processed both within the EEA and on secure servers to provide the best possible user experience, for example to quickly build a website or mobile application. The data of OLX users in the EEA is stored on cloud servers provided by Amazon Web Services, Inc. located in Dublin, Ireland.

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, tax and accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and applicable legal requirements.

We retain the personal data associated with your account for as long as you are a registered user or until you delete your account, in which case we will ensure that your data is deleted without undue delay and as soon as technically feasible. Depending on the Service you have used and the systems in which your data is stored, it may take a maximum of 3 months from the date of your request to delete your data. During this period, all access to your data will be restricted or blocked immediately.

If there has been no activity on your account for a period longer than 24 months, we will close your account in accordance with our  Terms of Service  and delete all personal data stored on your account, meaning that you will no longer have access and you use them. However, we will not close your account and delete your data if you have any pending open transactions or are entitled to repayment of funds credited to your account either by you or by us. Before closing your account, we will notify you to give you a chance to keep your account active, for example by logging into your account.

After your account is closed, we may retain certain data to the extent necessary (i) to fulfill our legal obligations, such as for tax, accounting and auditing purposes, or (ii) to settle a legal claim or dispute, or to comply with a request by an authority (for example, in relation to law enforcement). We will only retain data that is relevant for such purposes and will delete it after the applicable retention or limitation periods have expired or after the relevant legal purpose has been fulfilled.

For customer safety and security and fraud prevention purposes, we may retain certain data related to your closed account, such as your ad lists, your IP address, moderation information, and user experience information, for a maximum period of 14 months after closure .

Personal data related to cookies are stored for the period corresponding to the life cycle of the type of cookie or until deleted by you. You can read more about this in our  Policy on cookies and similar technologies .

If you have any questions about the retention period of your data, please contact us via  the contact form .

13. Technical and organizational measures and security of  upstream processing

All information we receive about you is stored on secure servers and we have implemented technical and organizational measures that are appropriate and necessary to protect your personal data. OLX continually evaluates the security of its network and the adequacy of its internal information security program, which is designed to (a) help protect your data against accidental or unlawful loss, access or disclosure, (b) identify reasonably foreseeable risks to OLX’s security c) minimizing security risks, including through risk assessment and regular testing. We also ensure that all payment details are encrypted using SSL technology.

Please note that despite the measures we have taken to protect your data, the transfer of data over the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.

14. Links to Third Party Websites  Upstream

Our Services may contain links to third-party websites or applications. If you click on any of these links, please note that they will each have their own privacy policy. We do not control these websites / apps and are not responsible for these policies. When you leave our Services, we encourage you to read the privacy notice of each website you visit.

15. Contacts  up

For further information or to exercise your rights, please check your account / privacy settings or contact our privacy office using our  contact form  or via  the Help Center . You can also contact the data controller for your local services at: Sofia 1000, Sredets district, str. Angel Kanchev 1. Naspers Classifieds Bulgaria EOOD.

16. Data protection  up

For data protection complaints, you can contact the responsible data protection authority. You can exercise this right by contacting the authority of your place of residence or place of work or the location of the data controller.

For Bulgaria, the relevant data protection authority is: 

Commission for the Protection of Personal Data

Address: Blvd. Tsvetan Lazarov 2, 1592 Sofia

Telephone:

• For inquiries on complaints, alerts and questions: 02 / 91-53-519; fax 02 / 91-53-525;
• For consultations on the implementation of Regulation (EU) 2016/679 and national data protection legislation: 02 / 91-53-555

Website: http://www.cpdp.bg/

For cross-border data processing programs, our main supervisory authority  is the Dutch Data Protection Authority  in the Netherlands:

Autoriteit Persoonsgegevens

PO Box 93374

2509 AJ Den Haag, The Netherlands