In accordance with the provisions of EU Regulation No. 679 of April 27th, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (hereinafter referred to as “General Data Protection Regulation” or “GDPR”), of the internal regulatory acts approved in view of the implementation of the EU General Regulation, the Company KMGR Services Center SRL, an entity within the KMG International Group, having on the one hand the capacity of Data Processor for the data controllers that can be Companies of KMG International Group  ( and Agents operating the Rompetrol Downstream SRL gas stations, and, on the other hand, on own behalf in its capacity of personal data controller, is processing your personal data, in safety conditions, in good faith, and in compliance with the legal provisions in force, exclusively for the fulfillment of the purposes specified in the current Information Memorandum.

In your capacity of person interested (hereinafter known as "Data Subject" or “Candidate”)  on the recruitment process for employment/internship  in one of the  KMG international Group Companies or for one of the Agents operating the gas stations of Rompetrol Downstream SRL (hereinafter "the Company" or “Controller”),the Controller  brings to your attention, expressly, by the herein Information Memorandum, in compliance with articles 12 and 13 of GDPR, with regards to the processing and storage of your personal data in the conditions described, as follows:

1.         Personal data:

(a)   General Information on the registration of the Resume in our database: name, first name, date of birth, marital status, telephone number and email address, nationality, citizenship, gender and details, and details on any disabilities or work restrictions, photo of the data subject, any other information contained in the resume posted by you on the

(b)   Selection checks: Recommendations/request for recommendation, interview notes, records/results of the verifications/tests, including technical and psychometric tests (measures the abilities, skills, behaviors or personality traits of the Data Subject).

2.         Personal data processing purposes:

Your personal data is processed by the Controller for human resources purposes, for purposes related to the recruitment and selection process, in your capacity of Candidate, for occupying one of the existing or future vacancy jobs/functions/positions or for the carrying out of an  current/future internship program. The data processing is made in compliance with article 6 para. 1) letter a) of the EU General Data Protection Regulation, the consent for participation in the recruitment process;

In the case where the Controller shall decide upon processing your personal data for other purposes, namely based on article 6, paragraph 1, letter a) of the EU General Data Protection Regulation, and of the internal normative acts approved in view of implementing the EU General Regulation, respectively based on your consent, you will be sent a separate information memorandum, thus allowing you to express your consent, freely.

3.         Data processing duration:

During the purposes related to the human resources activity as indicated in point 2 above, your personal data will be stored for a limited period of time in a safe place, in compliance with the legal conditions and provisions, as follows:

  • The data from your resume,  the interview report, the  tests results  but also all the information communicated by you shall be kept for 6 months from your last login on the website;
  • If applicable, the data on psychometric tests platform is kept 6 months from the completion of the respective test.  

4.           Data Processors/Data Recipients:

Your personal data may be processed by the following persons, with the observance of the law on personal data protection:

i. The Companies within the KMG International Group performing activities for the Company in the domain of work relationships or to which the Company reports the results of its activity, respectively, but not limited to KMGR Services Center, KMG Rompetrol S.R.L.

ii. Agents operating the gas stations of Rompetrol Downstream SRL or of other entities within the KMG International Group, in their capacity of Controller in the case where the application is submitted for an open position within the gas stations;

iii. IT services and systems providers, such as Total Soft S.A., SAP, SmartDreamers SA, as well as GREAT PEOPLE INSIDE SRL, 42 Organizational Assessment, Predictive INDEX LLC, psychometric tests providers, all the companies under these categories with which the Company shall contract this type of services and which have taken adequate safeguarding measures, as per the legal provisions, in order to ensure that they are observing their obligations on personal data protection. In the case where associated controllers subcontract part of their activities involving the processing of personal data, the subcontractors shall be subject to be same obligations with regards to the implementation of the security, technical, and organizational measures provided for by the EU General Data Protection Regulation, but also of the internal normative acts approved with a view to implementing the EU General Regulation;

5.         Personal data transfer:

Personal data may be transferred (e.g. accessed, consulted, etcetera) to other companies within the KMG International Group headquartered in countries outside the EU, on the basis of your direct application for a vacancy position within the respective entity or of your contacting, with a view to initiating, concluding, and developing certain labor or internship contracts, and/or projects with those companies. To this end, the guarantees provided for by articles 44-49 of the General Data Protection Regulation shall apply.

6.         Your rights with regards to personal data:

Furthermore, we wish to inform you that, as per articles 12-22 of the EU General Data Protection Regulation and of the internal normative acts approved with a view to implementing the EU General Regulation, you have the following rights:

i.          the right to information and to access your personal data;

ii.         the right to the rectification of your data;

iii.         the right to be forgotten /the right to data deletion;

iv.         the right to restrict the processing;

v.         the right to data portability;

vi.        the right to object to the processing of your data, in the case of the personal data processed in accordance with Article 6 paragraph 1) letter e) or f), including the creation of profiles based on these provisions, respectively for the fulfilment of a task performed for public interests or within the exercise of an official authority with which the data controller is vested, respectively to the Company’s legitimate interests;

vii.       the right not to be subject to any individual decision, which means that you have the right to request and obtain the retraction, cancellation and reconsideration of any decisions which produces legal effects on you, adopted solely based on an operation of personal data processing through automated means, for the purpose of assessing personality traits, such as professional skills, credibility, your conduct at the workplace;

viii.       the right to withdraw your consent  at any given moment, without it having an impact on the processing performed based on your consent before its retraction;

ix.        the right to notify the National Supervisory Authority for Personal Data Processing or any competent courts of law.

In order to exercise all these rights, you may contact the Company by a request sent at the email address [email protected] (Romania), [email protected] (Bulgaria). Your request will be analyzed, and you will receive a reply within at most 30 days from the receipt of your request by the Company, as per the EU General Data Protection Regulation and the internal normative acts approved with a view to implementing the EU General Regulation. The term mentioned hereinbefore for sending a reply may be extended in accordance with and with the observance of the legal provisions.

7.         Other aspects:

The controller guarantees the fact that your data is processed legitimately, by concurrently implementing adequate technical and organizational measures for ensuring the integrity and confidentiality of the data as per articles 25 and 32 of the EU General Data Protection Regulation.

8.         Expresing your consent:

The consent for the processing of your data according to the purposes described in point 2 above is expressed by creating the account and voluntarily uploading your personal data in the recruitment application on the website provided by the Controller, your agreement being explicit and freely manifested by checking in the "Accept" box and only after reading and understanding this Information Memorandum.