Personal Data Processing Notice – Candidates

1. Introduction

The company PULSEC doo Beograd (hereinafter referred to as the Company) (hereinafter referred to as the Company), in accordance with this privacy policy (Privacy Policy), prescribes the ways in which the Company may collect and process your personal data.

The Company may collect and process your personal data when interacting with you regarding employment/recruitment or for other purposes, or when you visit our website. Acting in accordance with applicable laws, in particular the Law on Personal Data Protection (hereinafter: the Law), including the EU General Data Protection Regulation (hereinafter: “GDPR” or “Regulation”), we are highly committed to data protection and maintaining the privacy of all collected information.

2. Contact

3. Data collection

We may collect and process your personal data when you have provided it to us yourself, when we have obtained it from publicly available sources, and on the basis of recommendations.

Category of persons whose data is processed – Candidates, whether they apply during an active competition for the selection of candidates, or have sent personal data to the Controller as part of their resume (CV), in any way (in paper form, via email, via platforms where the Controller has published a job advertisement, etc.), in order to be potentially considered in one of the competitions.

4. Purpose of processing and information we process

We may collect and process your personal data for the following purposes:

  • In order to fulfill our contractual obligation to you. This information may include your name, address, email address, telephone number, occupation, job title, company, type of cooperation with us;
  • For the purpose of recruitment and selection of new employees, either for specific jobs or for potential future positions; this information may include your name, address, email address, telephone number, date of birth, information about your education and experience, CV, data collected for the purpose of processing tests in the selection process, photograph (if you provide it yourself) and other relevant information;
  • In order to respect and comply with legal obligations.

5. Legal basis for processing and storing personal data in accordance with the Law on Personal Data Protection (Official Gazette of the Republic of Serbia 87/2018) and the GDPR regulation

We will process personal data in accordance with the following legal bases:

  • in order to execute a contract with you in accordance with Article 12, paragraph 1, item 2) of the Law and Article 6 (1)(b) of the GDPR regulation;
  • the legal basis also includes our legitimate interest in accordance with Article 12, paragraph 1, item 6) of the Law, Article 6 (1)(f), when you communicate with us regarding employment opportunities or in order to improve our website;
  • when we have your consent in accordance with Article 12, paragraph 1, item 1) of the Law, Article 6 (1)(a) of the GDPR regulation, where necessary;
  • in order to comply with the legal obligations to which we are subject in accordance with Article 12, paragraph 1, item 3) of the Law and Article 6 (1)(c) of the Regulation.


We may make your personal data available to our affiliated companies and in other cases regulated by the Law and the GDPR regulation.

6. Transparency of personal data processing

In accordance with Article 23, paragraph 2 of the ZZPL, additional information that the data subject should be aware of is:

a) We will keep your personal data that we process for the purpose of employment opportunities for as long as it is necessary for the purpose for which it was collected, i.e. for as long as it is necessary to fulfill all applicable legal obligations, and for a maximum of 2 years. As a personal data provider, you have the right to delete personal data that you exercise by submitting a request for deletion.

b) The data subject retains all rights provided for by the applicable ZZPL, and in particular the right to access, correct, or delete his/her personal data, the right to restrict processing, the right to object, as well as the right to data portability. The data subject is warned that, if he/she requests the Controller to delete his/her personal data, he/she may be prevented from participating in the competition for the selection of candidates, i.e. he/she will not be taken into account when considering future open positions.

c) The data subject has the right to revoke the consent given for the processing of his/her personal data at any time, provided that the revocation of consent does not affect the legality of the processing of personal data until the moment of formally expressed will by which the given consent is revoked. As in the case of deletion of personal data, if the consent is revoked, the data subject may be prevented from further participation in the competition, i.e. he/she will not be taken into account when considering future open positions.

d) The person retains the right to, in case he/she believes that his/her rights guaranteed by the applicable ZZPL have been denied, contact the Commissioner for Information of Public Importance and Personal Data Protection (address: Bulevar kralja Aleksandra 15, 11000 Belgrade, Serbia), by submitting a complaint in the prescribed procedure.

e) Providing personal data for the needs and for the purpose of conducting the competition procedure for the selection of candidates by the Controller is not a legal or contractual obligation of the data subject. In case of refusal to provide personal data for the stated purpose to the Controller, the person may be prevented from further participation in the competition for the selection of candidates and will not be taken into account when considering future open positions.

f) The controller does not apply methods for automated decision-making or profiling in cases of collecting and processing personal data for the purposes of competitions for the selection of candidates, as well as in cases of selecting candidates for engagement who have sent their personal data outside of the announced competition.

g) In accordance with the provision of Article 23, paragraph 3 in connection with Article 6, paragraph 1. i 2. ZZPL, for each processing of personal data for other purposes, except for the one for which the data was given, and which is not permitted by the law itself, the data subject will be adequately informed before starting data processing actions, with familiarization with all legally prescribed information and rights that belong to him/her on that basis.

7. Data protection and security

We take all precautionary measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal data is stored and require our data processors to protect your personal data through contractual means.

8. Contact for exercising rights

If you want to exercise any of your rights as described above or have any questions, please contact us via email [email protected] or by letter to the address according to Article 2 of this notice.

The person in charge of contact regarding personal data protection will respond to each inquiry as soon as possible, depending on the inquiry itself, but no later than 30 days from the date of proper receipt of the inquiry. That deadline may be extended by an additional two months as needed, taking into account the complexity and number of requests.

9. Changes to the privacy policy

In case of changes to the Privacy Policy, we will publish the new, updated version of the Privacy Policy on the appropriate website, and it can also be delivered to you upon your request.