Legal

Privacy Policy

Last updated: 23 May 2025

HR Academy (“we”, “us”, “our”) is a sub-brand of Astrea Recruitment Ltd., operating the website at https://hracademy.bg. This Privacy Policy explains what personal data we collect when you use our website, why we collect it, how we use it, and what rights you have under the General Data Protection Regulation (GDPR) and applicable Bulgarian data-protection law.

1. Data Controller

The data controller responsible for your personal data is:

2. What Personal Data We Collect

2.1 Waitlist sign-up

When you join the waitlist we collect:

  • Your email address
  • The date and time of sign-up

2.2 Contact form

When you submit our contact form we collect:

  • Your name
  • Your email address
  • The message you write

2.3 Analytics and usage data

We use Google Analytics 4 and Microsoft Clarity to understand how visitors interact with the website. These tools may collect:

  • Pages visited and time spent
  • Device type, browser, and approximate location (country/city)
  • Anonymised IP address
  • Click, scroll, and navigation behaviour (Clarity heatmaps)

IP addresses are anonymised before being sent to Google Analytics. Neither tool is configured to collect personally identifiable information.

3. How We Use Your Data

PurposeData usedLegal basis (GDPR Art. 6)
Notify you when HR Academy opens enrolmentEmailConsent (Art. 6(1)(a))
Respond to your contact-form enquiryName, email, messageLegitimate interest (Art. 6(1)(f))
Improve website performance and user experienceAnalytics dataLegitimate interest (Art. 6(1)(f))

4. How We Store Your Data

Waitlist email addresses are stored in a secure, append-only file on our private server hosted in the European Union. Contact-form submissions are not stored server-side — they are forwarded directly to our team by email and then deleted from the mail queue.

5. Third-Party Services

We use the following third-party processors, each bound by a Data Processing Agreement with us:

  • Resend (email delivery) — used to send transactional emails. Resend may temporarily process your email address on servers within the US and EU under Standard Contractual Clauses.
  • Google Analytics 4 — anonymised website analytics. Data is processed by Google LLC (US) under Standard Contractual Clauses. See Google's Privacy Policy.
  • Microsoft Clarity — session recording and heatmaps (anonymised). Processed by Microsoft Corporation (US) under Standard Contractual Clauses. See Microsoft's Privacy Statement.
  • DigitalOcean — our server and infrastructure provider. Data is stored on EU-region servers.

We do not sell your personal data to any third party.

6. Cookies

Our website uses the following cookies:

  • Google Analytics cookies (_ga, _ga_*) — expire after 2 years. Used to distinguish unique visitors and sessions.
  • Microsoft Clarity cookies (_clck, _clsk, MUID) — expire after 1 year. Used for session replay and heatmap analysis.

You can opt out of Google Analytics at any time using the Google Analytics Opt-out Browser Add-on. You can also control cookies through your browser settings.

7. Data Retention

  • Waitlist emails— kept until you request deletion or until 12 months after HR Academy's public launch, whichever comes first.
  • Contact-form messages — kept in our team inbox for up to 24 months or until the enquiry is resolved, whichever comes first.
  • Analytics data — retained for 14 months in Google Analytics (our configured retention period). Clarity data is retained for 30 days by default.

8. Your Rights Under GDPR

Under the GDPR you have the right to:

  • Access — request a copy of the personal data we hold about you.
  • Rectification — ask us to correct inaccurate data.
  • Erasure (“right to be forgotten”) — request deletion of your data.
  • Restriction — ask us to limit how we use your data.
  • Portability — receive your data in a machine-readable format.
  • Objection — object to processing based on legitimate interest.
  • Withdraw consent — where processing is based on consent (e.g. the waitlist), you may withdraw at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email us at academy@hracademy.bg. We will respond within 30 days. You also have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (CPDP).

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include server-side access controls, encrypted HTTPS transport, and restricted staff access.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. Continued use of the website after changes are posted constitutes acceptance of the revised policy.

11. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us: