Draft. This text is under legal review and may change.

Privacy notice

Version 0.4 · Last updated: 24.09.2026

This notice explains how ARA.BG EOOD processes personal data when you visit ai-people-hub.com, request a demo, become a partner or use AI People Hub as a user of a company account.

1. Who the controller is

ARA.BG EOOD (АРА.БГ ЕООД), company number (ЕИК) 203301726. For any question about personal data: office@ai-people-hub.com.

2. When we are a controller and when a processor

The employee and candidate data a company enters into AI People Hub (personnel files, leave, pay, applications and so on) is processed on behalf of that company. The company is the controller of it and we are its processor under Article 28 of Regulation (EU) 2016/679 (GDPR) — the terms are in the Data processing agreement. If you are an employee or a candidate of one of our customers, please address your request to them; we will assist them.

This notice covers the data for which we decide why and how it is processed, described below.

3. What we process, why, and on what basis

WhenDataPurposeLegal basis (GDPR)
Visiting the websiteIP address, browser, requested page, timeSecurity, abuse prevention, diagnosticsLegitimate interest — Art. 6(1)(f)
Statistics on the public pagesPage address, referrer, device and browser type; with your consent, also Google Analytics cookies (_ga) — see the Cookie policyAggregated traffic statisticsWithout cookies — legitimate interest, Art. 6(1)(f); with cookies — consent, Art. 6(1)(a), which you may withdraw at any time
Your choice in the cookie bannerA random ID, the choice made, the policy version, the page, the time — no IP addressTo demonstrate that consent was given (Art. 7(1))Legal obligation — Art. 6(1)(c)
A demo request or an HR service partner applicationName, company, work email, phone, number of employees, interest, services, message, partner code, IP address and browserTo contact you and present the productSteps prior to a contract — Art. 6(1)(b); legitimate interest — Art. 6(1)(f)
Ideas and votes on the public roadmapName and email with a suggestion; votes are counted by a hashed IP addressTo review the idea and reply; one vote per visitorLegitimate interest — Art. 6(1)(f)
The referral partner programContact and company details, referred clients, commission earned, payment details (IBAN) and, for individuals, the personal number (ЕГН) for tax purposesThe partner contract, commission payouts, accountingContract — Art. 6(1)(b); legal obligation — Art. 6(1)(c)
A user account in a company profileName, email, role, sign-in data, two-factor authentication, activity and security logProviding the service, account security, supportThe contract with your employer and our legitimate interest — Art. 6(1)(b) and (f)
BillingPayer contact details, company details, payment historySubscription and invoicesContract — Art. 6(1)(b); legal obligation — Art. 6(1)(c)
SupportThe content of the request and contact detailsTo answer the requestContract or legitimate interest — Art. 6(1)(b) and (f)

We do not sell personal data or use it for advertising profiles. We make no automated decisions with legal effects about website visitors.

4. How long we keep it

5. Who receives the data

We use providers who process data on our behalf and on our instructions:

The full list of sub-processors for our customers' data is in the Data processing agreement. We may also disclose data to public authorities where the law requires it.

6. Transfers outside the EU

Our servers and backups are in the EU. Google (statistics and AI features) and Stripe (payments) belong to groups based in the United States, and data they handle may be processed outside the European Economic Area. Both are certified under the EU–US Data Privacy Framework, and their data processing terms also include the European Commission's standard contractual clauses.

7. Your rights

You have the right of access to your data, to rectification, erasure, restriction of processing, portability, and to object to processing based on legitimate interest. Where processing relies on consent, you may withdraw it at any time.

Write to office@ai-people-hub.com. We reply within one month and may ask you to confirm your identity.

You may lodge a complaint with the Bulgarian Commission for Personal Data Protection — 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, www.cpdp.bg — or with the supervisory authority where you live.

8. Security

The connection to the site is encrypted (HTTPS). Sensitive documents and fields (personal numbers, ID cards, IBANs) are stored encrypted. We maintain role-based access control, two-factor authentication, audit logs and encrypted backups.

9. Changes

We may update this notice. The date and version at the top show the latest change; we will notify registered users of material changes.