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    Personal data protection

    Dear customer, dear business partner

    This information on protection of personal data and privacy applies to you and your personal data because you are our customer or business partner. Our company acts as an operator in processing of your personal data.

    We want to explain to you how we are going to use personal data that we will receive from you or third parties during the term of our contractual relationship and after its termination.

    With this document we would also like to fulfil our obligation to provide information pursuant to Article 13 of the Regulation of the European Parliament and the Council (of EU) no. 2016/679 from April 27, 2016 on protection of natural persons when processing personal data and on free movement of such data, which terminates the Directive 95/46/EC (General Data Protection Regulation) and Act no. 18/2018 Journal of Laws from November 29, 2017 on personal data protection and on amendments of some statues

    Operator’s Identification Data:
    Fucikova 456
    925 21 Sladkovicovo
    Registration number: 36 667 633
    VAT identification number: SK 2022232278
    Registered with the Business Register in Trnava, section : Sro, Insert No. 18923/T
    Executive Director: Mgr. Marian Machalec, CEO
    (hereinafter “Operator”)


    1. Types of personal data

    We are processing the following data:

    • Personal contact data. For example, your name, surname, permanent address, correspondence address, email address, contact telephone number.
    • Working contact data. For example, address of the company that you are representing, job’s email address and telephone number.
    • Contractual data. For example, content of contract concluded with our company including all its addenda, extent of provided services.
    • Information on payment.
    • Data on correspondence and communication. For example, email correspondence, Internet data transmissions and IP address.
    • Accession data. Your accession rights to various applications within the IT infrastructure.
    • Registration data including your access password.
    • Information connected to security.


    2. Purpose and goals of data processing

    We are going to process your data for the following purposes:

    • Provision of contractual services. We have to keep records on our clients pursuant to specific rules. Legal grounds is fulfillment of Operator’s legal duty.
    • Customer administration. We are keeping records on all our customers and their services. We also make decisions on offers for our customers based on the analysis of our records. Legal grounds is the contract conluded between us and legitimate interest of the Operator.
    • Direct marketing. We deal with how to improve the development of our services of providing tailored offers to you. Legal grounds is the legitimate interest of Operator.
    • Taxes and bookkeeping. We are obliged to process certain personal data for the purposes of fulfillment of duties arising from the Tax Law and other regulations connected to financial implementation. Legal grounds is fulfillment of legal obligations.
    • Safety of and threat to the operation and network. We monitor the operational functionality, safety and stability of our network, whose participant you are, as well. Legal grounds is fulfillment of legal obligations and legitimate interest of the Operator.
    • Settling of disputes and investigation of offences. We can process personal data for the purposes of settling of disputes, complaints or legal procedures or if we have a suspicion of offence that we would like to further examine. Legal grounds is fulfillment of legal obligations and legitimate interest of the Operator.
    • Honouring of the law. We might maybe have to process your personal data in order to honour the law (e.g. If your name matches with names on the so-called lists of designated parties and honouring of the anti-money laundering act) or in order to comply with an injunction.


    3. Who has acces to your data

    Operator may share your data with third parties under these circumstances:
    We can share your personal data with other third parties that act in our name, for example, with provider of services. In these cases, the third parties can use your personal data only for the abovementioned purposes and only in accoradance with our instructions. We have contractually obliged then to honour the safety instructions set forth by the law.

    Our employees will have acces to personal data. Only those will have an access, who need it for their work for the abovementioned purposes and only if the employee is bound by the non-disclosure obligation.

    If the law or injunction demands it, we can share your personal data with, for example, our suppliers or clients, tax authorities, social security services, law enforcement authorities or other governmental authorities.


    4. Placement of your personal data

    Your persona data will be placed solely within the European Union and the European Economic Area. We are protecting your data in our systems in the highest possible degree.


    5. Retention of personal data

    We retain your personal data for a limited time and these data will be deleted when they will no longer be needed for the processing purposes.  In most cases, this means that we are retaining your data during the term of your relationship with us. If possible, we will delete the data during your relationship with us as soon as they are no longer needed. In any case, your personal records will be deleted when the statutory deadlines expire after the termination of contractual relationship the latest unless the legislation demands their retention.

    We can process your personal data for a longer period after the termination of relationship in case of an ongoing legal dispute or if you had granted a permission for a long-term retention of your personal data to us.


    6. Legal grounds for processing of your personal data

    In most cases, we process your personal data on the basis that the processing is necessary for the purposes of a legitimate interest that we are pursuing, on contractual grounds or on the basis of your approval as an involved person. You can withdraw your approval anytime you want by a provable notice on our webpage.  In many cases, we will also have to process your personal data on the grounds of legal duty as defined in special rule. In case of approval-based processing, you always have an option to withdraw your approval.


    7. Rights of the involved persons

    It is important for you to understand that it is your data that we are processing and that we want you to be informed about it. Even though we do not need your permission to process your personal data because the law  or laws connected to our contract require us to do so, you have a lot of rights when it comes to processing of your personal data. Text above will answer most of your questions.


    Your rights

    Right to access

    You can request information on how we are processing your personal data, including the information on:

    • Why we are processing your personal data
    • What categories of personal data we process
    • With whom we share your personal data
    • How long we are retaining your personal data or what are the criteria for this period of retention
    • What rights you have
    • Where we get your personal data from (if we did not get them from you)
    • Whether the processing includes automated decision-making (so-called profiling)
    • Whether your personal data have been transferred to a country that is outside the EEA and how we are going to secure the protection of your personal data.

    All the abovementioned information are avaialble in this document.

    You can also ask for a copy of the personal data that we are processing. However, additional copies will not be free of charge.

    Right to correction

    It is important that we have correct information on you and therefore, we are asking you to inform us if any of your personal data is incorrect, for example, if you have changed your name or moved.

    Right to deletion

    If we are processingy your data unlawfully, for example, if we are processing your personal data for a longer period that is needed or without reason, you can ask us to delete these data.

    Right to restriction of processing

    Since the moment you have asked us to correct your personal data or if you had reservations towards the processing until the moment when we can investigate the problem or confirm

    the accuracy of your personal data (or change them in accordance with your instructions), you have a right to a restricted processing. This means, that we (with exception of personal data retention) can process your personal data only in accordance with your approval and only if it is needed in regards to legal entitlements, protection of someone else’s rights or if there is a significant public interest in their processing. You can also ask for us to restrict the processing of your personal data if the processing is unlawful, but yout do not want us to delete the personal data.

    Right to object

    If you think that we have no right to process your personal data, you can object against our processing. In these cases, we can continue processing only if we can prove convincing justified reasons that will outweigh your interests, rights and freedoms.  However, we can always process your personal data if it is needed for determination, application or defense of legal entitlements.

    Right to transfer of data

    You can ask for your personal data that you had given us for the purposes of processing with your approval or for purposes of performance of contract to be provided to you in a structured, commonly used and machine-readable format. You have also right to ask for such information to be transferred to another data administrator.

    Withdrawal of approval

    You have a right to withdraw your approval and we will subsequently stop our processing activities on the basis of this legal reason.

    We will also inform other parties, which we could have provided with your personal data, about your request/requests.

    In case of doubts, you have a right to bring an action pursuant to § 100 of the Act on Personal Data Protection to respective Surveillance Authority, for example, via www.dataprotection.gov.sk.

    How can I complain regarding the processing of my data and how do I exercise my rights?

    If you want to file a complaint about the way we are processing your personal data also in relation to the abovementioned rights, you can contact us at our email address gdpr(at)sminlo.com and your incentives and requests will be examined.

    If you are dissatisfied with our answer or if you think that we are processing your data unfairly or unlawfully, you can make complaints with respective Surveillance Authority, i.e. Office for Personal Data Protection (ÚOOÚ). Further information about the ÚOOÚ and the procedure for filing a complaint can be found here: www.dataprotection.gov.sk.


    8. Contact Info

    If you have any further questions regarding processing of your personal data, you can contact us via our correspondence address listed on our website www.sminlo.com or via email at gdpr(at)sminlo.com