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Privacy Policy

PRIVACY POLICY (MojPosao.ba)

Thank you for using the services of the MojPosao.ba portal!

We are an online guide to fast employment, and our mission is to enable job seekers to establish quick and efficient contact with companies offering jobs, while at the same time helping companies looking for employees to find suitable candidates as quickly and easily as possible (“Services”). For the purpose of fulfilling our mission, we collect personal data about job seekers and representatives of companies seeking employees, and we collect company data about companies themselves.

The MojPosao.ba website is owned and operated by Alma Career BH d.o.o. Sarajevo (“Alma Career”, “we” or “us”), which respects the privacy of visitors to its websites and takes care to protect the confidentiality of their data. For this purpose, this Privacy Policy has been created and applies only to activities on websites owned by Alma Career. The collection, storage, and transfer of personal data are carried out in accordance with the provisions of the Law on the Protection of Personal Data of Bosnia and Herzegovina (Official Gazette BiH No. 12/25), which regulate the protection of personal data, their transfer, and the prevention of unauthorized access to and use of personal data.

To help you understand what personal data we collect, how we use it, and what rights and choices you have, this Privacy Policy describes how personal data is processed on the MojPosao.ba portal (“Privacy Policy”) in accordance with applicable data protection laws. If you have any questions, please contact us at info@MojPosao.ba or our Data Protection Officer at DPO-BH@almacareer.com.

Please note that in certain cases Alma Career acts as a processor when processing job seeker personal data on behalf of an employer that acts as the controller (e.g., for specific recruitment). In other cases, Alma Career acts as the controller (e.g., when a job seeker or employer registers on MojPosao.ba, or when a job seeker uploads their CV to Alma Career’s databases).

How do we collect personal data?

When you visit the MojPosao.ba portal, you may knowingly and voluntarily leave personal data about you and your personal characteristics that are relevant for employment, or you may leave company data that is relevant for recognising the company in the market and for contact details. At the same time, when you visit MojPosao.ba, you also leave certain technical data related to the network systems you use to access the internet or a website (and in some cases such technical data may constitute personal data, such as an IP address). We collect data exclusively in accordance with our Terms of Use and this Privacy Policy.

We collect personal data and company data through:

Your voluntary submissions

Job seekers voluntarily provide their personal data through:

  • Independent registration on the portal – you visit MojPosao.ba and choose “Register”, and you store your personal data in the jobseeker database. To complete registration, you must activate your account via the link sent to your e-mail address. After signing up, you can adjust your newsletter settings as you wish, manage your profile, and upload documents (e.g., your CV and other attachments). Please see the available options after signing up. Please note that if you sign in using Facebook, we will receive certain personal data from Facebook in line with the authorisations you provide through that service.
  • Independent application to a published job advertisement – when applying to a job posted by an employer on MojPosao.ba, you submit your personal data through the portal. Please note that our platform also includes job ads that redirect you directly to the employer’s website and to an application form where you enter your details directly.
  • Independent registration in the internal database of the MojPosao.ba Agency – when you contact the MojPosao.ba Agency and request assistance with finding a suitable job and/or you apply via a job ad link that leads to the internal Agency database, you store your personal data directly in that database. However, a specific privacy policy applies to this processing (available on the respective website).
  • Application as an unregistered (non-registered) job seeker – you can apply using “Apply to job ad” without creating an account; in that case you provide at least your name, e-mail address, phone number and the personal data/documents you submit, and the application is routed through our servers to the employer.

Representatives of companies seeking employees voluntarily provide their personal data and the company’s data through:

  • Registration on the portal – a company representative visits MojPosao.ba, selects “Register”, and registers the company in the employer database. To complete registration, you must activate your account via the link sent to your e-mail address.
  • Publishing a job advertisement – by sending a request for publication / posting an ad.
  • Information provided during our interactions, such as call.

Employers may also provide candidate personal data through portal tools:

  • “Add application” option – an employer can add (upload) a candidate’s application to a job ad if that application arrived through another channel (e.g., direct contact, post, etc.). In such case, the employer has the obligation to inform the candidate that the candidate’s personal data is being stored in the MojPosao.ba system for that recruitment process. MojPosao.ba does not use those uploaded candidate personal data for any other purpose and does not contact such candidates for recruitment by other employers.

We collect technical data through:

Your visit to MojPosao.ba

Regardless of whether you are a job seeker or a company representative, at the moment you open MojPosao.ba we record certain technical data such as:

  • Cookies – used primarily for user login/authentication and security. We use cookies to store a user/session identifier to verify authenticity and help protect accounts. More information is available via our Cookie Settings / Cookie Policy.
  • Web server logs – like most websites, we automatically collect technical data such as IP address (except where otherwise described), date and time of visit, pages/links opened, the page you came from, browser type, operating system, and the domain/address of your internet service provider.
  • IP address – IP addresses are typically dynamic, but in some cases may be static and could be linked to a device/connection. We use IP addresses mainly for aggregated usage records, website improvement, and - if misuse occurs - to help identify the source of misuse together with the ISP and/or competent authorities.

What do we actually do with your personal data?

We use the data collected through MojPosao.ba to respond to requests you send us and, from time to time, to better understand your needs and improve our pages, products, and services. We may use your personal data to contact you and/or provide you information about our products or Services. In other words, we use your personal data for the purpose of delivering the Services to you - job seekers and representatives of companies seeking employees.

Personal data are processed both manually and automatically. There is no automated decision-making in the processing of personal data. We may personalise job offers and/or marketing communications based on profiling, where you have consented to this.

In addition, the following operational details apply (so the Privacy Policy fully reflects how the portal works in practice):

·       If you are a job seeker, you store your personal data in our databases for the purpose of finding suitable employment. As part of our Services to employers (domestic and foreign companies interested in candidates), we forward your CV/profile (personal data) to those companies in the context of recruitment mediation and job applications.

·       When you apply to a job ad through MojPosao.ba, we forward to the employer (the recipient of your application):

a) your MojPosao.ba candidate profile (personal data);
b) your contact details from your profile (e-mail and phone number); and
c) the documents you attached (CV, cover letter, certificates, etc.).

·       We store data about your job applications mainly so that:
a) you can later view/search the jobs you applied to through MojPosao.ba, and
b) for statistical purposes.

·       CV database access by employers/HR agencies: registered employers, our MojPosao.ba Recruitment Agency and HR agencies that have been granted access can search the CV database and contact candidates. However, a specific privacy policy applies to this processing (available on the respective website).

·       Important note about employers’ use of your personal data: employers who receive your application/CV may store and use your personal data in line with applicable law, their own privacy rules, and their contractual obligations. If you delete your CV/account on MojPosao.ba, we cannot guarantee that an employer has not already saved your personal data.

·       If you apply as an unregistered (non-registered) job seeker, your application personal data is sent to the employer through MojPosao.ba servers.

·       If you are a company/employer, you store your company data and the personal data of your representatives in our databases for the purpose of recruiting employees. After your expressed interest/need, we may contact you to define the type of Service you want and to deliver information about potential candidates.

·       “Add application” by employer: if an employer uploads a candidate’s application received outside MojPosao.ba, we process those candidate personal data solely to help that employer manage recruitment in one place.

·       Technical data and website statistics: we review server logs and other technical data to understand usage and improve the Service. In case of misuse, we may use technical data (including IP address where applicable) in cooperation with your ISP and/or authorities to identify the source of misuse.

Please note that we also process statistical data that cannot identify you.

On what legal basis do we process your data?

We process personal data to provide the Services you request (registration, job applications, recruitment tools), to comply with legal obligations, and where needed based on your consent (e.g., where consent is required for certain communications or transfers), as well as for legitimate interests such as security, preventing misuse, and improving the portal.

Depending on the specific Service you use and the relationship between you, Alma Career, and the relevant employer, we rely on one or more of the following legal bases:

·       Performance of a contract / taking steps at your request – we process personal data where this is necessary to provide the Services you request or to take steps at your request prior to entering into a contract. This includes user registration, enabling job applications and forwarding applications to employers, enabling employers to publish job advertisements and use recruitment tools. This legal basis applies to both job seekers and employers, especially where processing is necessary to provide the Services under the Terms of Use accepted by the user.

·       Legal obligation – we process personal data where necessary to comply with legal obligations applicable to Alma Career (for example, accounting and tax obligations, responding to lawful requests of competent public authorities, and retention obligations required by applicable regulations). This applies primarily to employers.

·       Legitimate interests – we may process personal data where necessary for the legitimate interests of Alma Career, provided that such interests are not overridden by your interests or fundamental rights and freedoms. This may include, for example, ensuring the security of the portal and user accounts, preventing misuse and unauthorised access, investigating suspicious activity, establishing, exercising or defending legal claims, and improving the functionality and quality of our Services and processing the personal data of individuals who act on behalf of an employer but are not its statutory representatives. Where we rely on legitimate interests, you have the right to object in accordance with applicable law.

·       Consent – we process personal data based on your consent where consent is required under applicable law or where we choose to rely on consent as the legal basis. This may include, for example, receiving newsletters or marketing communications (where consent is required), personalising job offers and/or marketing communications based on profiling (where you have consented), and the use of non-essential cookies and similar technologies (where consent is required). You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

·       Controller / processor roles (important clarification): In certain cases Alma Career acts as a processor when processing job seeker personal data on behalf of an employer that acts as the controller (e.g., for specific recruitment and/or job application processes). In such cases, the employer determines the purposes and legal basis for processing as controller. In other cases, Alma Career acts as the controller (e.g., when a job seeker or employer registers on MojPosao.ba, or when a job seeker uploads their CV to Alma Career’s databases), and Alma Career determines the purposes and legal bases described above.

How long do we keep your personal data?

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy and in accordance with applicable law. Retention periods may vary depending on the Service used, the category of data, and whether Alma Career acts as controller or processor. Where possible, we delete data; alternatively, we anonymise it so it can no longer be linked to an individual.

General rule: unless stated otherwise below, we keep personal data until you withdraw consent or request deletion, unless a longer retention period is required or justified under applicable law (e.g., accounting/tax obligations) or is necessary for the establishment, exercise, or defence of legal claims.

Retention by purpose:

·       Account registration and account administration (job seekers and employers) – retained while your account is active and for up to 2 years after inactivity/termination (unless you request deletion earlier).

·       Job applications submitted through MojPosao.ba (registered job seekers) – retained to enable you to view your application history and for statistical purposes while your account is active, unless you delete your account earlier or a longer retention is required for legal claims or compliance.

·       Job applications submitted without an account (non-registered applicants) – retained for the recruitment process.

·       CV database / candidate profile availability to employers – retained while you keep your CV/profile active and available in the database; you may remove your CV at any time.

·       Customer support, enquiries and communications – retained for as long as necessary to respond, resolve the request, and document the outcome; typically up to 2 years after closure of the request, unless a longer period is required for dispute handling or legal claims.

·       Newsletters, job alerts, marketing communications, and profiling-based personalisation (where consent applies) – retained until you unsubscribe or withdraw consent, and then only a minimal suppression record (e.g., your e-mail and opt-out status) is kept to ensure we respect your preference not to receive further messages.

·       Website logs, technical data, and analytics/measurement (including DotMetrics, where enabled) – retained for the minimum period necessary for security, troubleshooting, and service improvement, and then deleted or anonymised. Where possible, we use aggregated statistics that do not identify individuals.

·       Security, fraud prevention, and misuse investigations – retained for as long as necessary to investigate, prevent recurrence, and support legal action, and may be retained longer where required to establish, exercise, or defend legal claims or to comply with lawful requests from authorities.

·       Accounting, invoicing, contractual and compliance records (primarily employer/company data and related personal data of representatives) – retained for the period required by applicable accounting/tax and other mandatory laws and regulations; after expiry of mandatory retention, data are deleted or anonymised.

·       Legal claims and disputes – where necessary, we may retain relevant personal data for the duration of the dispute/claim and any applicable limitation periods, and then delete or anonymise it.

Important note (employers as independent controllers): where your personal data are transferred to employers (e.g., via a job application or CV database access), those employers may retain your data under their own retention policies and legal obligations. Requests for deletion of data held by an employer must be addressed to that employer as controller.

Recipients of personal data

Personal data are made available only to authorised employees/workers of Alma Career, to individual processors, or to other recipients acting as separate (independent) data controllers, such as public authorities.

Processors have only limited access to personal data, and only to the minimum extent necessary. No processor is authorised to use the personal data provided for its own purposes (marketing or otherwise); processors are contractually obliged to comply with this restriction.

In cases stipulated by law, the controller may, and in some cases must, disclose certain personal data to public authorities or law enforcement bodies in accordance with applicable legal regulations. For this reason, we may also be obliged to provide the required information, including personal data, to the relevant public authorities.

Specific examples:

·       Audience measurement (DotMetrics): For research on website visitation, we cooperate with Fistnet d.o.o. (DotMetrics), in cooperation with Ipsos d.o.o., who collect web visitation data. DotMetrics’ privacy policy is available at https://dotmetrics.net/documents/policy.pdf.

·       Sharing with service providers/partners: We may share personal data and/or company data with associates or partners of Alma Career where necessary for Services they perform for or with Alma Career (e.g., database maintenance, data processing services, and sending requested information). Such parties may not use the data for any other purpose.

·       Sharing with third parties for recruitment mediation: We may forward your personal data to third parties where such transfer is related to employment mediation or other job-related activities on the site.

·       International transfers / group sharing: Company data may be transferred outside Bosnia and Herzegovina to companies within the Alma Media group, including Alma Media Oy (Finland), for the purposes of international sales of products and in accordance with applicable law. Transfer of job seeker personal data to EU/EEA countries occurs only where you have expressed an interest in finding work outside Bosnia and Herzegovina in a specific country (e.g., where an employer outside BiH wants to contact you).

Use of our services by minors

Children cannot use our services. Minors who are 15 or older may use our services only with explicit written consent of a parent/guardian, in accordance with labour-law legislation in Bosnia and Herzegovina.

Sensitive and other data

We never request personal data that is not necessary for the specific purpose of the job seeker, such as an ID card number, copies of identity documents, or any other unnecessary documents.

Alma Career does not request sensitive data unless it is necessary for a specific Service and permitted by law. If sensitive data are processed, this will occur only where one of the applicable legal grounds for special categories applies (for example, your explicit consent or another legal basis permitted under applicable law).

Please note that each job seeker is obliged to consider in advance whether - and to what extent - medical and/or other sensitive data are provided, in particular where the provision of such data is not required by the relevant form in connection with a specific Service.

What can you do with your personal data stored in our databases and what RIGHTS do you have?

You can change your personal data at any time in your account, and if you are a job seeker you can determine the scope in which your personal data is used (for example, you decide which data are included in your CV, except for data that are required by the relevant form). You also have the option to delete your account and your personal data. However, this does not mean that company data will no longer be processed, for example for tax and accounting purposes, in accordance with applicable regulations.

Rights can be exercised in writing by a letter sent to the registered office of Alma Career or by e-mail to DPO-BH@almacareer.com.

Right of access

You have the right to be informed whether your personal data are being processed and, if so, to obtain access to your personal data.

Please note that if a job seeker wishes to obtain information regarding personal data processed by a potential employer acting as the controller, the job seeker must contact that employer directly, as Alma Career is in that case acting as a processor.

Right to rectification

If you consider the personal data processed by Alma Career to be inaccurate, incorrect, outdated, or incomplete, you have the right (and in certain cases the obligation) to request that it be rectified or completed. Alma Career shall rectify and/or complete the data without undue delay, taking into account technical limitations.

Please note that you can update your data through the software functionalities of the relevant Service.

Right to erasure (“right to be forgotten”)

If you request the erasure of data, Alma Career shall erase your personal data if:
(i) the data are no longer necessary for the purposes for which they were collected;
(ii) you withdraw consent or object to the processing and there are no overriding legitimate grounds for the processing;

(iii) the processing was unlawful; or

(iv) erasure is required to comply with a legal obligation, or the data were collected in relation to the offer of information society services.

Please note that we will delete personal data that we process as a controller. For personal data processed by our clients/employers acting as controllers, you must request deletion from those employers. For example, if you respond to a job posting, the controller is the relevant potential employer.

It is also important to note that the “right to be forgotten” is not absolute. If we have an objective obligation to retain certain data (e.g., for accounting purposes), we will delete only the personal data that are no longer required for the original purposes of processing and will retain only what must be kept under applicable law.

Right to restriction of processing

If you do not wish to erase the data but only to temporarily restrict the processing of your personal data, you can request that we restrict the processing of your personal data.

You have the right to restriction of processing if:
(i) you dispute the accuracy of the data, for the period necessary for the controller to verify the accuracy of the personal data; or
(ii) the processing is unlawful and you oppose erasure of the personal data and request restriction of their use instead; or
(iii) Alma Career no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise, or defence of legal claims; or
(iv) you have objected to processing, pending verification whether the legitimate grounds of Alma Career override your interests, rights, and freedoms.

Right to data portability

If you wish to transfer your personal data processed by Alma Career, where such processing is based on your consent or an agreement, to another controller, you may exercise your right to data portability. If the exercise of this right would adversely affect the rights and freedoms of third parties, Alma Career may not be able to comply with such a request.

Right to object

You may object to the processing of personal data that is carried out for the purposes of the legitimate interests of Alma Career or of third parties. If Alma Career does not demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, we will stop the processing based on the objection without undue delay.

If your objection relates to the sending of commercial communications, you may object via the hyperlink provided in the marketing message. You may also object to marketing at any time by ticking the relevant checkbox (if available) or by sending an e-mail with the subject line STOP to DPO-BH@almacareer.com.

Right to withdraw consent

If personal data are processed based on your consent, you may withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to contact the Data Protection Authority

Agency for Personal Data Protection in BiH (AZLP)
Address: Dubrovačka br. 6, Sarajevo
Tel: +387 33 726 250
E-mail: azlpinfo@azlp.ba

Right to an effective judicial remedy

Without having to first file a complaint with the supervisory authority, you have the right to judicial protection against any data controller or processor. In line with GDPR principles, every natural person has the right to judicial protection against the controller or processor if they believe that their rights have been violated as a result of processing of personal data contrary to applicable data protection rules.

Please note that, in the event of repeated or manifestly unfounded requests to exercise rights, Alma Career is entitled (in line with GDPR Article 12(5) principles) to charge a reasonable fee for the exercise of the right in question or to refuse to comply with such a request. Alma Career shall inform you of such steps in advance. We will promptly acknowledge receipt of your request and process it within the one-month time limit set by applicable rules, or we will inform you of the reasons for any extension.

You may also exercise the rights set out above with any controller who processes your personal data, i.e., the relevant employer.

Security

Certain areas of MojPosao.ba that collect your personal data use HTTP protocol and SSL encryption for data transfer (provided your browser supports encryption). MojPosao.ba uses its own and third-party hosting centres. These hosting centres protect your data with standard firewall protection and intrusion detection software.

Final provisions

Alma Career reserves the right to modify these Privacy Policies depending on changes in the provided Services and/or if there are changes in legal regulations that require modifying the relationships differently. Minor adjustments, such as formatting, typo correction, or text clarification, can be made without the need to change the date of the last update.

In accordance with the guidelines of the European Data Protection Board, we will announce significant or substantial changes/processes that could be surprising or unexpected for you, through MojPosao.ba.

Contact details

If you have any questions about this Privacy Policy or our website, please contact:

Alma Career BH d.o.o. Sarajevo
Pehlivanuša bb, 71000 Sarajevo, Bosnia and Herzegovina

Central office: +387 33 204 592
E-mail: info@MojPosao.ba

You can also contact our Data Protection Officer: DPO-BH@almacareer.com

For technical/support questions, including unsubscribe assistance: podrska@mojposao.ba, +387 33 846 965.

Your use of this website is also subject to the Terms of Use.