Personal data protection

1. Introduction

Alma Career North Macedonia DOOEL Skopje, with its registered office at Debarca Street No. 10, 1000 Skopje, is an organization with a long-standing tradition of providing services to entities operating in the labor market. The strategic goal of Alma Career North Macedonia DOOEL is to ensure financial and economic stability, to improve the quality of services, to build strong relationships with its partners, and to enhance the company’s reputation.

The achievement of these goals depends on the continuous improvement of management quality, as well as the efficiency of services based on modern information technologies. We are aware that the security and protection of personal data are an essential part of using such technologies.

Through this Privacy Policy, Alma Career North Macedonia DOOEL prescribes the necessary and economically appropriate measures for the protection of the information system, individuals, and data, as well as the implementation of security mechanisms in the technologies it uses.

The management of Alma Career North Macedonia DOOEL is responsible for properly assessing risks and effectively managing them concerning the protection of data and systems necessary for the smooth operation of the organization. The primary goal is the prevention, management, and timely recovery from security incidents.

To protect its vital and internal infrastructure, the company, in cooperation with experts, applies security measures tailored to the latest standards and the organization’s needs. These measures include technical and organizational actions aimed to:

• ensure the availability, integrity, and reliability of systems through modern IT solutions;
• protect commercial and personal data from loss, damage, theft, alteration, or destruction, and to preserve the confidentiality of processed information;
• identify and prevent potential problems and sources of risk.

Alma Career North Macedonia DOOEL has established appropriate technical and organizational measures to ensure a high level of protection in the processing of personal data (including DPIA – Data Protection Impact Assessment). The company has developed a security project that is regularly updated and defines the methods and scope of measures necessary to minimize threats and risks that may affect its information systems.

The company processes personal data exclusively in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation – GDPR). Alma Career North Macedonia DOOEL acts as the data controller.

This document contains the basic rules for processing personal data when providing services through the website www.mojaplata.mk (“Website”). Alma Career North Macedonia DOOEL reserves the right to amend or supplement this Policy, whereby all changes will be promptly published on the Website with the effective date clearly indicated.

All relations not regulated by this Policy shall be governed by the General Terms and Conditions of Use of Alma Career North Macedonia DOOEL and the applicable laws of the Republic of North Macedonia.

This Policy is aligned with the provisions of Regulation (EU) 2016/679 and is permanently available at www.mojaplata.mk.

2. Definitions

Personal data means any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Data Subject means a natural person to whom personal data relate.

Data Controller means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by European Union law or national law, the controller or the specific criteria for its nomination shall be defined by such law.

Client means a natural or legal person who uses or intends to use the services provided through the Website.

What personal data do we collect and why do we process it? To properly process your order and provide quality service, we need to know your e-mail address, since the services of Alma Career North Macedonia DOOEL are provided through electronic communication.

3. Principles of Data Processing and Security

Personal data must be:

• processed lawfully, fairly, and transparently in relation to the data subject (“lawfulness, fairness, and transparency”);
• collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes (“purpose limitation”);
• adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate data are erased or rectified without delay (“accuracy”);
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (“storage limitation”);
• processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by using appropriate technical or organizational measures (“integrity and confidentiality”).

The Data Controller is responsible for compliance with these principles and must be able to demonstrate such compliance (“accountability”).

Lawfulness of Processing

The processing of personal data shall be lawful only if and to the extent that at least one of the following conditions applies:

• the data subject has given consent to the processing of their personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which the controller is subject;
• processing is necessary to protect the vital interests of the data subject or another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, particularly where the data subject is a child.

Obligations of the Data Controller

The Data Controller undertakes to:

• define, prior to processing, the purpose of processing personal data, which must be clear, unambiguous, and lawfully determined, in accordance with the Constitution and laws of the Republic of North Macedonia;
• ensure that the conditions for processing do not restrict the rights of the data subject;
• collect personal data solely for a specific and legitimate purpose, without any hidden or alternative intent;
• process only those personal data whose scope and content are appropriate and necessary for achieving the stated purpose;
• ensure that personal data are processed and used only in a manner consistent with the purpose for which they were collected;
• destroy or anonymize personal data once the reason for their processing no longer exists. Data may be further processed only for scientific, historical, or statistical purposes, and only in anonymized form.

4. Data Processing on the Website

Visitors to the Website may easily compare their salaries or order a salary analysis by filling in a short online form that specifies the job position and region.

Visitors may also enter their e-mail address when completing the online salary comparison form. Since an e-mail address may be considered personal data under the Regulation and the Law, it is important that the data subject gives consent before submitting it.

The e-mail address of the data subject is used for periodic (quarterly) delivery of salary comparison results processed by the Data Controller. Consent may be withdrawn at any time; otherwise, it expires one year after being given, upon which the data will be deleted. Requests for withdrawal of consent can be sent to szop@almacareer.com or to the company’s business address: Alma Career North Macedonia DOOEL, Debarca Street No. 10, 1000 Skopje, North Macedonia.

What personal data do we collect and why do we process it?

To correctly handle your order and provide a high-quality service, we need your e-mail address, as our services are provided through electronic communication.

The user may also give explicit consent for the use of personal data for a longer period. In such a case, the data will be used exclusively for statistical monitoring of salary trends, without any disclosure or sharing with third parties. The user may withdraw their consent at any time by following the link contained in the e-mails received.

Cookies

Cookies are small data files that are stored on the user’s device (computer, tablet, mobile phone, etc.) when using the Website. Alma Career North Macedonia DOOEL uses cookies to monitor the functionality and performance of the Website.

Cookies do not contain personal information that identifies an individual; they serve to recognize the browser or device used. Some cookies are temporary and are deleted once the browsing session ends, while others remain stored on the user’s device for a longer period.

Data collected through cookies may include the browser type, IP address, operating system, and the web address from which the Website was accessed. For the purpose of displaying more relevant ads, third-party advertising systems such as Google Ads may use cookies, which can be disabled through the user’s Google account.

Users can configure their browser to refuse cookies, but in that case, some functionalities of the Website may not be available.

5. Data Subject Rights

The Data Controller shall take appropriate measures to provide the data subject with all the information referred to in Articles 13 and 14 of the Regulation, as well as all communications under Articles 15 to 22 and Article 34 of the Regulation related to data processing. The information shall be provided in a concise, transparent, intelligible, and easily accessible form, using clear and plain language, particularly when addressed to children.

Information may be provided in writing or electronically. Upon request of the data subject, the information may also be provided orally, provided that the identity of the data subject is verified.

The data subject has the right to obtain confirmation from the Data Controller as to whether or not personal data concerning them are being processed, and, where that is the case, to access such personal data and the following information:

• the purposes of processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the data have been or will be disclosed, in particular recipients in third countries or international organizations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the Data Controller the rectification or erasure of personal data, restriction of processing, or the right to object to such processing;
• the right to lodge a complaint with a supervisory authority;
• the source of the personal data if not collected directly from the data subject;
• the existence of automated decision-making, including profiling.

The data subject has the right to request rectification of inaccurate personal data without undue delay and to request completion of incomplete personal data.

The data subject has the right to request from Alma Career North Macedonia DOOEL the erasure of their personal data (“right to be forgotten”). Any consent for the processing of personal data given to Alma Career North Macedonia DOOEL may be withdrawn at any time.

Requests for erasure or withdrawal of consent may be sent to the e-mail address: szop@almacareer.com.

The competent supervisory authority is the Agency for Personal Data Protection of the Republic of North Macedonia, where the data subject may lodge a complaint if they believe their personal data have been processed unlawfully.