Purposes, legal bases, and retention
| Data / activity | Purpose | Legal basis | Typical retention |
|---|---|---|---|
| Application data | Assess the application, communicate, interview, match, and take requested steps before a program agreement | Steps at your request before entering a contract; legitimate interests in administering a fair selection process; legal obligations where applicable | Normally 6 months for unsuccessful initial applications; longer for selected participants under the retention schedule |
| Enquiries | Respond to questions and manage the relationship | Steps at your request; legitimate interests in communication and service administration | Normally 12 months after resolution |
| Technical and security data | Deliver and protect the website, prevent abuse, diagnose faults | Legitimate interests in secure and reliable services; legal obligations where applicable | Normally up to 30 days |
| Website analytics | Measure aggregate use of the website — pages viewed, referrers, devices, outbound clicks — to understand what is useful and improve it | Legitimate interests, Art. 6(1)(f) GDPR, in understanding how the site is used. No consent is sought because the measurement is cookieless: nothing is stored on or read from your device, so there is no terminal-equipment access requiring consent | Aggregated reports retained for trend comparison; individual visit records removed on the configured schedule |
| Language preference | Remember the language you selected | Necessary service function — the preference is stored only because you asked for that language | Up to 12 months |
1. Scope and controller
AMERA Global Career Development, Sofia, Bulgaria, is the controller for the processing described in this notice. Questions and requests can be sent to office@amera-corporation.eu.
This notice covers the public AMERA website, program enquiries, and applications. A host company that later receives candidate information may act as an independent controller for its own recruitment or placement decisions and must provide its own information where required.
2. Personal data we process
We do not ask for special-category data, national identification numbers, financial information, or medical information in the initial application. Please do not place such information in your CV or notes.
- Application information: name, email address, telephone number if provided, field of study, CV or résumé, and optional notes.
- Enquiry and correspondence information: your contact details, messages, and our responses.
- Technical and security information: IP address, browser and device information, requested pages, timestamps, and security events that may be recorded by the hosting infrastructure.
- Website analytics information: pages viewed, referring page, approximate location, browser and device type, and interactions such as outbound link clicks, recorded by our own Matomo installation. Your IP address is shortened before it is stored, and no cookie or other identifier is placed on your device.
- Preference information: the language you selected.
3. Where the data comes from
Most data comes directly from you. Basic technical and security data may be generated automatically by your browser, our hosting infrastructure, or strictly necessary site functions. If a university, referrer, or partner provides information about you, we will give you the information required by law unless an exception applies.
4. What is required
Fields marked as required are needed to assess and respond to an application. Telephone information and free-text notes are optional at the initial stage. If required information is not provided, we may not be able to assess the application. No cookie or other storage on your device is required to browse or apply, and none is used for analytics.
5. Who may receive personal data
We do not sell personal data. Processor names must be added to the internal processor register and this notice updated where transparency requires identification of a provider.
Website analytics is not shared with anyone. We run Matomo ourselves, on our own server, and no analytics provider, advertising network, or other third party receives the data.
- Authorised AMERA team members who need the information for application administration, communication, security, or legal compliance.
- Contracted hosting, email, document-storage, application-management, and professional-service providers acting under appropriate confidentiality and data-processing terms.
- Prospective host companies and program partners, but only at an appropriate stage, only with relevant information, and after you have been informed where required.
- Public authorities, courts, advisers, or insurers where disclosure is required by law or necessary to establish, exercise, or defend legal claims.
6. International transfers
The program involves potential host organisations in Japan. If candidate data is transferred to an eligible recipient in Japan, AMERA will rely on the applicable European Commission adequacy framework where its conditions are met. Otherwise, an approved transfer mechanism and any necessary supplementary safeguards will be used before transfer.
Service providers outside the European Economic Area may be used only after their transfer mechanism, sub-processors, data location, and contractual safeguards have been reviewed.
Website analytics involves no international transfer. The Matomo instance runs on our own server in the European Union and the data does not leave it.
Commission Decision (EU) 2019/419 on Japan adequacy ↗7. Retention
Data is deleted or anonymised when it is no longer needed. Final production periods must be matched to the actual systems and documented in AMERA’s retention schedule.
- Unsuccessful or withdrawn initial applications: normally up to 6 months after the relevant cohort decision, unless a shorter period is requested or a longer period is required for a legal claim.
- Selected participants: for the program relationship and afterwards for applicable contractual, accounting, tax, insurance, safeguarding, and limitation periods.
- General enquiries: normally up to 12 months after the enquiry is resolved, unless needed for an ongoing relationship or legal claim.
- Security logs: normally up to 30 days, with longer preservation only where needed to investigate an incident or meet a legal obligation.
- Website analytics: aggregated reports are kept so that trends can be compared over time. Individual visit records are held only for as long as needed to produce those reports and are then removed on the schedule configured in our Matomo instance.
8. Website analytics
We measure how this website is used with Matomo, which we host ourselves on our own server in the European Union. The measurement is first-party: no analytics company, advertising network, or other third party receives the data, and it is not transferred outside the EEA.
Matomo runs here without cookies. It stores nothing on your device and reads nothing from it — no cookie, no local storage, no device fingerprint — which is why this website shows no cookie banner for analytics. Your IP address is shortened before it is stored, so the records cannot be traced back to your connection.
We rely on our legitimate interests under Art. 6(1)(f) GDPR to understand how the site is used and improve it. Because nothing is placed on or read from your device, no consent is required for this measurement.
- If your browser sends a Do Not Track signal, we honour it and the visit is not recorded.
- You can object to this measurement at any time by contacting office@amera-corporation.eu, and we will act on your objection.
9. Your rights
To exercise a right, email office@amera-corporation.eu. We may ask for proportionate information to verify your identity. We normally respond within one month, subject to the extensions allowed by law.
- To be informed and to obtain access to your personal data.
- To correct inaccurate or incomplete data.
- To request erasure or restriction where the legal conditions are met.
- To object to processing based on legitimate interests and to object to direct marketing at any time.
- To receive data you provided in a structured, commonly used, machine-readable format where portability applies.
- To withdraw consent at any time where processing is based on consent, without affecting earlier lawful processing.
- To lodge a complaint with the Bulgarian Commission for Personal Data Protection or the supervisory authority in your country of residence or work.
10. Automated decisions
AMERA does not currently make application decisions solely by automated means and does not profile applicants for automated eligibility decisions. If this changes, the required information and safeguards will be provided before that processing begins.
11. Security and incidents
AMERA applies technical and organisational measures appropriate to the risk, including access limitation, secure transport, minimisation, supplier controls, and incident procedures. No internet service can guarantee absolute security.
Personal-data breaches are documented and assessed. Where required, AMERA will notify the competent authority within 72 hours of becoming aware and will inform affected people without undue delay when there is a likely high risk.
12. Changes to this notice
This notice will be updated when processing, providers, destinations, or legal requirements change. Material changes will be highlighted and, where necessary, communicated directly. The effective date at the top identifies the current version.
Contact and complaints
- Controller
- AMERA Global Career Development
- Address
- Sofia, Bulgaria
- Privacy contact
- office@amera-corporation.eu
You may complain to the Commission for Personal Data Protection (CPDP) in Bulgaria or to the data-protection authority where you live or work. We would appreciate the opportunity to address your concern first, but this does not limit your right to complain.
Commission for Personal Data Protection (CPDP) ↗